Core Differences and Response Strategies for Enterprise Accounting Treatment Under Export Tax Refund Policy Adjustments

Entering 2026,China’s foreign trade tax administration continues to deepen in the direction of digitization and precision.One notable manifestation is that the specific applicable boundaries of export tax refund policies have become clearer,the export tax refund rates of some commodities have been reduced to zero or adjusted,and the recognition and subsequent processing procedures for "non-refundable" situations caused by commodity classification,trade methods or enterprise qualifications have also become more standardized.This puts forward clear requirements for the financial departments of enterprises: they can no longer simply equate "export" with "tax refund",and must carry out differentiated accounting treatment based on policies and business essence.

I.Core Policies of 2026: Situations No Longer Eligible for Tax Refund

Policy adjustments mainly focus on commodity catalogs and compliance thresholds.Enterprises need to pay attention to two key changes.

1.Reduction or Adjustment of Refund Rates for Some Commodities

Based on domestic industrial development orientation and environmental protection requirements,tax authorities,together with the Ministry of Commerce,customs and other departments,will dynamically adjust the "Commodity Catalog of Non-Refundable Exports" or directly reduce the refund rates of specific commodities.For example,the export tax refund rates of some high-energy-consuming,high-polluting resource-based primary products may be reduced to zero in 2026.This means that enterprises exporting these commodities will not be eligible for any input VAT refund,and the relevant taxes shall be included in the cost.

2.Newly Added Specific Non-Refundable Situation List

In addition to the commodities themselves,the policy has also refined the situations that lead to non-refund due to operational problems.For example,where there are substantial differences between the declaration information on the customs declaration form (such as product name,specification,quantity) and the VAT invoice information and cannot be reasonably explained; another example is goods exported under specific supervision methods that have not completed relevant supervision procedures as required by the policy.Once any of these situations occur,even if the commodity itself is within the eligible refund catalog,the enterprise may lose the qualification for tax refund.

II.Dual Impacts on Enterprise Finance and Business

The tightening and clarification of tax refund policies is like a double-edged sword,which brings challenges while also containing opportunities for enterprises to transform and upgrade.

• Opportunities: The policy forces enterprises to manage their supply chains and production links more meticulously.By optimizing the product structure and shifting to high-value-added,high-tech products,enterprises can continue to enjoy stable tax refund dividends.At the same time,the clear "negative list" allows enterprises to avoid risks in advance,pre-place compliance costs,and avoid greater losses afterwards.
• Challenges: The most direct impact is the squeezing of profit margins.The originally refundable input VAT is converted into costs,which directly erodes gross profit.Secondly,the complexity of financial accounting has increased.Accountants must accurately distinguish the tax attributes of each export business and adopt different accounting treatment methods,which puts forward higher requirements for the enterprise’s financial internal control system.Finally,compliance risks have risen.Once the accounting treatment is wrong,enterprises may face tax refunds,fines and even credit rating downgrades from tax audits.

III.How Zhongshen’s Agency Services Can Intervene

Facing these changes,the value of professional foreign trade agencies has become prominent.When serving clients,Zhongshen will start from the following links to help enterprises make a smooth transition.

Before the business starts,our customs team will assist clients in conducting pre-classification review of commodities.Combined with the latest tariff schedules and refund catalogs,we will clarify whether the target commodity is eligible for tax refund and whether there is a risk of classification disputes.For example,a client of Mr.Hou planned to export a batch of new composite materials products.Our experts confirmed through pre-classification that it could be classified under a high-refund-rate tariff number,avoiding the risk of the enterprise applying a low refund rate or even non-refund due to incorrect self-classification.

For businesses confirmed as non-refundable,our financial team will guide clients to conduct accurate cost accounting and accounting initialization.The key is to reasonably allocate the corresponding input VAT (such as the VAT contained in raw material procurement and production energy consumption) to the cost of this batch of exported goods,and clearly mark it in the accounts to ensure the accuracy of tax accounting.

In the customs declaration and document links,we strictly implement the principle of "documents matching the goods and documents matching each other".Especially for non-refundable goods,we will separately prepare document circulation records to ensure that customs declaration data,logistics vouchers and internal financial vouchers can confirm each other,and prepare complete evidence chains for possible tax inspections.

IV.Refund vs.Non-Refund: Core Differences in Accounting Treatment

This is a key point that enterprise financial personnel must master.The accounting treatment logic of the two is fundamentally different,which is directly related to the presentation of the income statement and tax compliance.

Take an export of goods with a tax-included purchase price of 1.13 million RMB (including 130,000 RMB of input VAT) as an example.If the refund rate of this goods is 13%,the enterprise can apply for a refund of 130,000 RMB,which will be reflected as accounts receivable in the books.If the goods are clearly non-refundable,the 130,000 RMB input VAT shall be directly included in the goods cost,making the cost 1.13 million RMB,and the enterprise’s profit will decrease accordingly.

For foreign trade enterprises,under the current policy environment,a practical action suggestion is to immediately establish or update the enterprise’s "Dynamic Archive of Export Commodity Tax Attributes".This archive should not be a static table,but need to be linked to the latest tax refund policy library,recording the HS code,current refund rate,whether it is on the special list,and whether there have been classification or refund disputes in history for each type of export commodity.The financial department should share this archive with the business and customs departments,and first check and confirm the tax treatment method before accepting orders or purchasing goods,so as to avoid the passive situation of "finding that tax refund is not possible only after doing the business" from the source.When providing one-stop agency services for clients,Zhongshen will take the establishment and maintenance of such archives as one of the standard actions of pre-tax and finance health diagnosis,helping clients consolidate the bottom line of financial compliance.