Who exactly pays taxes under export agency model?

According to Article 18 of the 2025 Export Goods and Services VAT Management Measures, export agency adopts"Whoever operates, whoever declares"After the export enterprise receives foreign exchange through the agency company, it needs to provide:

• Export DrawbackDeclaration entity: Agency company holding export qualifications
• VAT taxpayer: Actual goods owner (consignor)
• Corporate income tax declaration entity:
  • Agency service fee income – Agency company
  • Profit from Goods Sales – Consignor

Does the consignor need to issue VAT special invoices?

The 2025 tax audit focus for export agency documentation chain must include:

• Consignor → Agent issues 13% VAT special invoice
• Agent → Foreign buyer issues commercial invoice
• The customs declaration form must clearly indicate the phrase "export on behalf of".

A 2024 case: A garment company in Zhejiang was deemed to have engaged in "fake self-operation and real agency" for failing to issue invoices to the agency company, resulting in the recovery of tax refunds and a fine of 1.2 million yuan.

How exactly are export tax refunds calculated and allocated?

Taking 2025 textile 13% refund rate as example:

• Agents declared refund base = Customs declaration amount × exchange rate
• The actual tax refund amount should be fully returned to the principal
• Agency service fees should be charged separately (recommended contract stipulation: 1-3% of customs declaration amount)

How does foreign exchange receipt and payment affect tax treatment?

According to SAFEs new policy in 2025:

• Must be processed through the agency companys foreign exchange accountA complete export agency agreement should be attached with:
• FX Settlement AgencyPayment to the principal must be completed within 5 working days
• The bank receipt must be annotated with "under agency export."

V. How to Avoid the Risk of "False Self-Operation, True Agency"?

Key violation characteristics targeted by General Administration of Customs in 2025:

• Agency fees below 50% of industry standards
• Fund circulation cycle exceeding 30 days
• Customs declaration form not indicating agency relationship
• It is recommended to clarify in the agency agreement:
  • Goods ownership transfer clauses
  • Quality responsibility division
  • Irrevocable payment authorization

VI.Cross-border E-commerceAre there any special regulations for agency exports?

Regarding the new cross-border e-commerce policy in 2025:

• Under 9710/9810 model, platform transaction data must be uploaded
• Retail exports under $150,000 per shipment can use simplified declaration
• Overseas warehouse goods must complete tax refund declaration within 6 months

How to prepare supporting documents for tax audits?

It is recommended that enterprises establish a "three-stream integration" archive:

• Goods flow: Customs declaration forms, shipping documents, warehousing records
• Fund flow: Foreign exchange receipts/payment vouchers, agency fee invoices
• Document flow: VAT special invoices, proforma invoices, foreign exchange verification forms

A compliance case: A machinery manufacturer in Suzhou achieved zero-issue audit in 2024 by real-time synchronization of three-flow data through ERP system.