---
title: "Can Export Tax Refund Enterprises Apply for Refundable Input Tax Credits? Policy Key Points Analysis - Zhongshen Trading China"
description: "With the continuous optimization of foreign trade policies in 2026，the coordination between export tax refunds and refundable input tax credits has become a focal point for enterprises. Many Shanghai-based foreign trade enterprises have inquired: Can export tax refund enterprises apply for refundable input tax credits at the same time? Director Yu from Zhongshen pointed out that the new policy clarifies the applicable conditions，but enterprises need to pay attention to compliance details. Agency..."
url: "https://www.sh-zhongshen.com/en/news/export-tax-refund-enterprise-refundable-tax-credit-policy-analysis.html"
language: "en"
type: "Article"
category: "Industry News"
datePublished: "2026-08-29"
dateModified: "2026-08-29"
brand: "Zhongshen Trading China"
image: "https://cndpic.sh-zhongshen.com/uploads/tradepics/ILnztRBsxtMWf.webp"
---

# Can Export Tax Refund Enterprises Apply for Refundable Input Tax Credits? Policy Key Points Analysis

## Key Points of the 2026 New Policy for Refundable Input Tax Credits for Export Tax Refund Enterprises

In February 2026,Director Yu from a Shanghai-based foreign trade company specializing in electronic product exports called Zhongshen,sounding confused: "Our company files export tax refund declarations every month,but we recently heard that we can also apply for refundable input tax credits.Can we do both at the same time?Will there be any conflicts?" In response to such questions,the new policy issued by the State Taxation Administration in January 2026 has given a clear answer.The core points can be summarized into 3 aspects:

![2026 New Export Tax Refund Policy: Can Export Tax Refund Enterprises Apply for Refundable Input Tax Credits?](https://cndpic.sh-zhongshen.com/uploads/tradepics/ILnztRBsxtMWf.webp)

- **Expanded Applicable Scope**: Breaking the 2025 restriction that "only production-oriented export enterprises can apply",foreign trade enterprises can apply for refundable input tax credits at the same time as long as they meet the requirement that "export business revenue accounts for ≥50% of total operating revenue" and their input tax has not been used for export tax refunds;
- **Simplified Process Coordination**: The precondition of "first complete the exemption,credit and refund declaration,then refund the remaining withheld tax" has been cancelled.Eligible enterprises can directly submit the refundable input tax credit application without waiting for the export tax refund audit;
- **Refined Compliance Requirements**: Enterprises need to provide 4 types of core documents including export customs declaration forms (special copy for tax refund),value-added tax special invoices (deduction copy),foreign exchange receipt vouchers,and proof of export business revenue proportion.False declarations will be included in the tax payment credit rating D,which will affect subsequent tax refunds.

## Opportunities and Challenges for Export Tax Refund Enterprises Applying for Refundable Input Tax Credits

After the implementation of the new policy,foreign trade enterprises in Shanghai and surrounding areas have gained financial benefits but also face higher compliance requirements:

### I.Opportunities: Easing Cash Flow Pressure and Reducing Capital Costs

In the past,it took an average of 15-20 working days for export tax refunds to arrive.Refundable input tax credits can arrive in as fast as 3 working days through the green channel.Take the clothing export enterprise served by Zhongshen as an example: in 2025,the company had 800,000 yuan of withheld input tax every month,and had to bear an additional 3,000 yuan of loan interest per month because it first handled the exemption,credit and refund declaration.After the new policy was implemented in January 2026,the company could directly apply for the refundable input tax credit,which arrived in the same month,saving nearly 20% of capital costs.

### II.Challenges: Increased Compliance Difficulty and Easy Declaration Deviations

Some enterprises have a vague understanding of "export business revenue proportion calculation cycle" and "input tax allocation".For example,they include entrusted processing fees in export revenue but fail to provide processing contracts,or mistakenly include domestic sales input tax in the withheld tax scope,leading to application rejection.The new policy clearly states that false declarations will be subject to joint disciplinary measures,and enterprises will face risks of fines and credit rating downgrades.

![Can Export Tax Refund Enterprises Apply for Refundable Input Tax Credits and How Much Cost Can Be Saved?](https://cndpic.sh-zhongshen.com/uploads/tradepics/ILqmAkQxncdxc.webp)

## How Zhongshen Helps Enterprises Accurately Implement the New Policy

With over 20 years of industry experience and the policy team led by Director Yu,Zhongshen provides full-process closed-loop services:

- **Pre-inspection: Confirm Eligibility**: Extract the enterprise’s export customs declaration and revenue data of the past 12 months,accurately calculate the export revenue proportion,verify the usage of input tax,and confirm whether it meets the new policy requirements;
- **Document Organization: One-stop Coordination**: Assist in organizing 4 types of core documents and 12 supporting certificates,and use the internal audit system to check for missing or incorrect documents to avoid tax rejection;
- **Declaration Agency: Green Channel**: Relying on long-term cooperation with the Shanghai Taxation Bureau,open green channels for eligible enterprises to submit applications first,shortening the audit cycle by an average of 5 working days;
- **Risk Warning: Dynamic Monitoring**: Issue a "Refundable Input Tax Credit Compliance Risk Report" every quarter to remind enterprises of changes in export revenue proportion,the deadline for input tax invoice certification,etc.to avoid compliance issues.

## Comparison of Policy Changes Between 2025 and 2026

| Policy Dimension | 2025 Requirements | 2026 New Policy Requirements | Enterprise Impact |
| --- | --- | --- | --- |
| Applicable Enterprise Type | Only production-oriented export enterprises | Production-oriented + foreign trade enterprises (export revenue proportion ≥50%) | Foreign trade enterprises gain new application qualifications |
| Application Precondition | Must complete exemption,credit and refund declaration | No exemption,credit and refund pre-declaration required | Tax refund arrival time shortened by 3-5 working days |
| Core Declaration Documents | 3 types of export tax refund documents | 4 types of documents for export tax refund + refundable input tax credit | Document preparation difficulty increased by 20% |
| Disciplinary Measures | Fine for false declaration (10,000-50,000 yuan) | Fine + tax credit rating D + joint disciplinary measures | Compliance risk significantly increased |

## Practical Suggestions: Complete Policy Inspection Before the End of March

For the 2026 first quarter refundable input tax credit declaration (deadline March 31),Shanghai-based foreign trade enterprises are advised to:

**Immediately contact Director Yu from Zhongshen to conduct pre-inspection of export business revenue proportion and input tax allocation**.Since the new policy requires "export revenue proportion ≥50% in the past 12 months",some enterprises whose export revenue fluctuated in the fourth quarter of 2025 need to adjust their declaration strategies in advance to avoid missing the first quarter tax refund window.Director Yu’s team can assist in sorting out the input tax invoice certification situation to ensure the accuracy of withheld input tax amount.

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