2026 Export Tax Refund Agent Fee Inclusion: Policy Interpretation and Practical Guide

Core Interpretation of 2026 Export Tax Refund Agent Fee Inclusion Policy

In 2026,the State Taxation Administration and the Ministry of Commerce jointly issued the *Notice on Optimizing Tax Administration of Export Tax Refund Agency Services*,which made three key adjustments to the rules for including export tax refund agent service fees,directly related to enterprises’ tax burden costs and compliance risks:

Policy Point 1: Clear Deduction Scope and Voucher Requirements

The new policy abolishes the rule applicable in 2025 and earlier that "agent service fees are deducted subject to a limit of 1% of export value".Eligible agent service fees can be fully recorded under "selling expenses - agency fees" and deducted before corporate income tax.At the same time,enterprises are required to provide three supporting documents when declaring: agency service contract,special VAT invoice for service fees,and service result confirmation form.The service result confirmation form must specify key information such as "successful export tax refund declaration,time of tax refund receipt" to avoid tax audits caused by ambiguous deductions.

Policy Point 2: Stacked Benefits for High-tech Enterprises

For high-tech enterprises whose coverage continues to expand in 2026,the new policy adds the benefit that "agent service fees can be combined with the super deduction of R&D expenses".If the export goods of an enterprise belong to high-tech products,the corresponding agent service fees paid can be included in the R&D expense category and deducted before corporate income tax at a rate of 175%.Note that this benefit only applies to service fees corresponding to high-tech product exports,and enterprises need to conduct separate accounting to avoid confusion.

Policy Point 3: Special Application for Cross-border E-commerce Enterprises

In 2026,the number of cross-border e-commerce comprehensive pilot zones has expanded to 30 cities across the country.For agent service fees for cross-border e-commerce B2B exports under the new policy,enterprises are allowed to record them under "main business costs" instead of selling expenses,while supporting documents are simplified (only platform transaction records and agent service fee invoices are required),which fits the export characteristics of "small batches,frequent shipments".

Opportunities and Challenges of the Policy for Export Enterprises

The 2026 policy adjustment brings tax burden dividends to enterprises,but also puts forward higher requirements for compliance management.The specific impacts can be analyzed from two aspects:

Opportunities: Lower Tax Burden + Improved Compliance Efficiency

• The average annual corporate income tax burden of traditional manufacturing enterprises can be reduced by about 8%-12%,and some enterprises with annual export value exceeding 50 million yuan can save more than 100,000 yuan in tax per year;
• High-tech enterprises with stacked super deduction can enjoy additional tax benefits of tens of thousands of yuan;
• Cross-border e-commerce enterprises have simplified accounting,and the tax refund declaration time is shortened by 2-3 working days.

Challenges: Upgraded Compliance Requirements + Difficulty in Accurate Adaptation

• Three supporting documents need to be retained simultaneously,and some enterprises cannot deduct fees due to ambiguous contract terms (unspecified service content);
• High-tech enterprises need to separately account for agent service fees corresponding to high-tech products,which is easy for financial staff to confuse;
• Cross-border e-commerce enterprises will face tax penalties if they mistakenly record B2C export service fees into main business costs.

How Zhongshen Helps Enterprises Implement the Policy

In response to the implementation needs of the 2026 new policy,Zhongshen relies on more than 20 years of foreign trade agency experience to provide enterprises with full-process services covering "policy diagnosis,data sorting,and accounting optimization":

1.Policy Adaptation Diagnostic Service

Supervisor Qiao from Zhongshen will first determine the applicable deduction policy type based on the enterprise’s export commodity category (whether it is a high-tech product) and business model (traditional trade/cross-border e-commerce).For example,a Shanghai-based electronic manufacturing enterprise had 60% of its exports as high-tech products in 2026.After calculating its agent service fees,Supervisor Qiao assisted the enterprise in including 60% of the service fees into the super deduction of R&D expenses,saving approximately 120,000 yuan in additional corporate income tax that year.

2.Compliance Sorting of Supporting Documents

Zhongshen will assist enterprises in optimizing agency service contract terms,clarifying service result indicators such as "export tax refund declaration success rate ≥99%,tax refund receipt cycle ≤7 working days",and simultaneously retain communication records (such as emails,WeChat chat records) during the service process as supplementary supporting evidence to avoid deduction failure due to incomplete materials.

3.Accounting Optimization and Risk Prevention and Control

In response to the questions of enterprise financial staff on the account subjects for recording service fees,Ms.Han from Zhongshen will combine accounting standards and tax policies to guide enterprises to accurately record into corresponding subjects according to business types:

• Traditional export agency service fees → Selling expenses - agency fees;
• Agency service fees for high-tech product exports → R&D expenses - other auxiliary expenses;
• Agency service fees for cross-border e-commerce B2B exports → Main business costs - cross-border e-commerce service fees.

At the same time,a service fee ledger will be established,and invoices and service results will be checked quarterly to prevent and control tax risks in advance.

Core Action Recommendations for Enterprises to Respond to the New Policy

Combined with the 2026 policy requirements,enterprises need to focus on the detailed compliance of service fee recording.The following table sorts out the mandatory quarterly actions:

The adjustment of the 2026 export tax refund agent fee inclusion policy not only brings tax burden dividends to enterprises,but also puts forward higher requirements for compliance management.Enterprises need to sort out their own business models in advance,and accurately adapt to the policy with the support of professional agency companies,so as to avoid affecting the enjoyment of tax preferences due to detailed omissions.