Complete Guide and Key Considerations for RMB FOB Price Declaration in Export Tax Refund

Export Tax Refund Declaration: Core Policies and Underlying Logic for RMB FOB Price Declaration

The declaration data of export tax refund is interlocking,among which the "FOB price" on the customs declaration form is the cornerstone for calculating the tax refund amount.Since the General Administration of Customs further deepened the tax collection and administration reform in 2025,the data linkage between the tax and customs systems has become closer,putting forward extremely stringent requirements for the consistency and rationality of declaration data.The declaration of RMB FOB price is no longer a simple number conversion,but a systematic project involving trade terms understanding,exchange rate application and document matching.A single declaration error may lead to automatic system rejection due to document discrepancy in mild cases,or trigger tax audit and affect the tax refund progress of the entire batch in severe cases.

The current policy environment emphasizes "data-driven supervision".Tax authorities use big data models to compare the enterprise’s historical export prices,industry average prices and major market fluctuations,and automatically alert abnormal quotations.This means that the RMB FOB price declared by the enterprise must not only be logically consistent internally,but also withstand horizontal and vertical data comparisons.

Key Point 1: Clear Declaration Caliber and Conversion Basis

The policy clearly stipulates that the FOB price used for tax refund declaration shall be subject to the FOB price specified on the export invoice (or proforma invoice).There is a common operational misunderstanding: many enterprises directly use the USD-denominated FOB amount on the customs declaration form and multiply it by an estimated exchange rate for declaration.The correct approach is to obtain the electronic information of the export goods customs declaration form,and strictly convert the foreign currency price to RMB price according to the middle rate of foreign exchange quotation released by the People’s Bank of China on the day of export or the first working day of the current month.

The key parameter is the choice of exchange rate.According to the Announcement of the State Taxation Administration on the Measures for the Administration of Value-Added Tax and Consumption Tax on Exported Goods and Services and relevant interpretations,once an enterprise selects the exchange rate on the 1st day of the export month or the exchange rate on the actual trading day,it shall not be changed within a natural year.This choice must be clearly defined and maintained consistently when the enterprise makes its first declaration,and arbitrary changes will become a concern for subsequent audits.

Key Point 2: Price Rationality Audit as a Focus

With the deepening of the "decentralization,regulation and optimization" reform,ex ante approval has been reduced,but in-process and ex post supervision has been unprecedentedly strengthened.The 2026 audit focus is increasingly focusing on the commercial rationality of the declared price.Especially for the following situations,the system will pay higher attention:

• Abnormal export price fluctuations of the same commodity in a short period without reasonable commercial explanation;
• Export prices significantly lower than the average price level of similar products in the same industry for a long time;
• Transaction pricing with affiliated companies that does not comply with the arm’s length principle.

Tax authorities will retrieve export data of similar goods in the same or recent period as reference.If the enterprise fails to provide evidence such as contract terms,market analysis reports and other documents supporting its special pricing,the relevant tax refund application may be suspended and enter the manual review channel.

Accurate Declaration of RMB FOB Price: Opportunities,Challenges and Responses for Enterprises

Accurate declaration of RMB FOB price directly and profoundly affects the enterprise’s cash flow and operational safety.Understanding its two-way impact is the prerequisite for effective tax management of enterprises.

From the perspective of opportunities,accurate and correct declaration is the "passport" for enterprises to enjoy efficient tax refund services.One-time data passing means that the tax refund funds can be returned to the enterprise’s account according to the normal cycle (currently the optimized process generally takes 1-2 weeks),effectively easing the capital pressure and improving turnover efficiency.In the highly competitive foreign trade environment,rapid cash flow recovery is itself a competitive advantage.In addition,long-term maintenance of high-accuracy declaration records will help enterprises accumulate good credit qualifications in the customs and tax systems,and may enjoy more convenient measures such as customs clearance and tax refund in the future.

However,the challenges are equally severe.The biggest challenge comes from the rising compliance costs.Enterprises need to establish or improve a collaborative mechanism among business,finance and customs departments to ensure that the FOB price expression and amount conversion are consistent in all links from contract signing,invoice issuance,customs declaration to tax refund application.This constitutes a high management threshold for many small and medium-sized foreign trade enterprises,especially factories or traders lacking professional teams.Another hidden challenge is the lag in policy understanding.Regulatory documents of the finance,taxation and customs departments are updated from time to time,and minor adjustments to the declaration system may also bring operational changes.If enterprises fail to keep up in time,they are very likely to follow old habits and make mistakes.

Zhongshen’s Agency Services: Translating Professional Capabilities into Practical Benefits for Clients

Facing the complexity and high risks of RMB FOB price declaration,the value of professional foreign trade agencies lies in translating policy provisions into executable,monitorable and traceable operating procedures.Based on over 20 years of practical experience,Zhongshen has built a full-link risk control and service plan for enterprises from the source of data to the arrival of tax refund funds.

Service Implementation 1: Pre-emptive Price Review and Document Calibration

Our service does not start after customs declaration,but is embedded in the customer’s order confirmation stage.Manager Zheng’s team will conduct a pre-review of the contract and invoice provided by the customer before making customs declaration documents.The focus is to check whether the trade term is FOB,whether the amount calculation is accurate,and conduct simulated conversion according to the latest exchange rate policy,so as to identify potential problems such as unclear price terms and chaotic currency amounts in advance.This "pre-intervention" model fundamentally avoids subsequent chain problems caused by basic document errors,ensuring that the FOB price on the customs declaration form is accurate and eligible for tax refund from the very beginning.

Service Implementation 2: Systemized Declaration and Discrepancy Handling Mechanism

We use our own information system to solidify the exchange rate application rules into the process.The system automatically grabs the official exchange rate,converts it according to the enterprise’s selected conversion method (1st day of the month or trading day),and generates the RMB FOB price data required for customs and tax refund declaration,ensuring that the whole process uses the same data source and consistent logic.When there is a slight difference between the customs statistical price and the declared price due to rounding and other reasons,our document personnel will issue a situation description and attach the calculation process as an attachment for tax refund declaration according to the regulations,effectively resolving the audit failure caused by the slight difference.

Service Implementation 3: Professional Support for Responding to Price Rationality Inquiries

When the export goods of customers have prices lower than the market conventional price due to special materials,custom processes,niche markets or clearance promotions,Zhongshen can provide key support.We will not only assist enterprises in sorting out a complete chain of evidence,including special contract terms,cost composition analysis,market pricing research reports,etc.but also issue a reasonable explanation letter in the capacity of a professional institution.Our senior consultants are familiar with the key concerns of auditors,and can communicate effectively in industry language,transforming the enterprise’s business behavior into logical evidence recognized by tax authorities,and protecting the legitimate tax refund rights and interests of enterprises.

Action Suggestions for Foreign Trade Enterprises

Whether entrusted with agency services or not,enterprises should establish internal control awareness of RMB FOB price.An immediately executable suggestion is: appoint a dedicated person (or department) to confirm and record the fixed conversion exchange rate for the current month on the first day of each month,and notify the relevant personnel of business,finance and customs.All export contracts,invoices and internal settlement documents concluded under FOB terms shall,when involving RMB pricing,mandatorily use this unified exchange rate for initial accounting and marking.This simple action can establish a unified price data foundation within the enterprise,greatly reduce subsequent troubles caused by chaotic exchange rate use,and lay a solid foundation for smooth collaboration with agency companies.