Can You Get Export Tax Refund Under EXW Terms? 2026 Policy Interpretation

Can You Get Export Tax Refund Under EXW Terms?Full Analysis of 2026 Policies

I.Breakdown of Core Points of 2026 EXW Export Tax Refund Policy

Many foreign trade enterprises ask whether export under EXW terms is eligible for tax refund.Director Han from Zhongshen,combined with the latest 2026 export tax refund policy,pointed out that EXW is not a "no tax refund" forbidden zone,but three core conditions must be met,none of which can be omitted:

• Goods must actually depart from Chinese customs territory.In 2026,the tax authority has strengthened the "verification of departure authenticity".Only providing customs declaration forms is not enough,and supporting documents such as bills of lading and manifests that prove the goods have left Chinese customs territory are required;
• Documents must be complete and consistent.In addition to conventional customs declaration forms and special VAT invoices,a "goods description consistency check" has been added: the name and specification of goods on the customs declaration form must fully match those on the VAT invoice and bill of lading,with an error of no more than 3 characters;
• Export enterprises must have general taxpayer qualification.Small-scale taxpayers cannot enjoy export tax refund even if they export under EXW terms,and can only apply for tax exemption.

In addition,the tax refund rates for some commodities remain stable in 2026: the refund rate for mechanical and electrical products (HS codes Chapter 84-85) remains 13%,11% for textile and apparel (HS codes Chapter 61-62),and 9% for agricultural products (HS codes Chapter 01-24),with no large-scale adjustments.

II.Impact of Tax Refund Policy Under EXW Terms on Enterprises: Both Opportunities and Challenges

Director Han analyzed that the 2026 policy has different impacts on different types of enterprises,with both opportunities and challenges:

Opportunities:

1.Reduce logistics costs: Under EXW terms,the buyer is responsible for the whole logistics process,so enterprises can save costs such as domestic transportation and port sundry fees.If they meet the tax refund conditions,it is equivalent to the dual benefits of "cost saving + tax refund acquisition";

2.Respond to the market flexibly: Some customers with small-batch orders prefer EXW.If enterprises can get tax refund in compliance with regulations,they can expand more customer groups and increase order volume.

Challenges:

1.Increased document complexity: The newly added goods description consistency check in 2026 makes it easy for enterprises to fail the tax refund review due to minor differences between invoices and customs declaration forms,such as minor wording differences in product descriptions;

2.Difficulty in obtaining departure certificates: If the freight forwarder designated by the buyer does not cooperate to provide a copy of the bill of lading,the enterprise cannot prove the departure of the goods,which directly affects the tax refund;

3.Deviation in policy understanding: Many enterprises mistakenly believe that EXW "does not involve export" and voluntarily give up tax refund,resulting in unnecessary profit loss.

III.How Does Zhongshen Help Enterprises Implement EXW Export Tax Refund?

In response to the pain points of enterprises in EXW tax refund,the team led by Director Han of Zhongshen provides targeted implementation services:

1.Pre-audit of documents: Before the enterprise signs the EXW contract,audit the goods description on the VAT invoice and purchase contract to ensure consistency with the subsequent customs declaration form,avoiding later rework;

2.Assistance with departure certificates: Liaise with the freight forwarder designated by the buyer,coordinate to obtain copies of bills of lading and manifest information,and ensure complete certificates of goods departure;

3.Tax declaration optimization: Utilize the 2026 "paperless tax refund" policy to submit documents quickly through the electronic port,and the average time for tax refund to be credited is 15 days shorter than that of enterprises’ self-declaration;

4.Policy compliance training: Regularly interpret EXW tax refund policies for customers.For example,a Shanghai-based garment enterprise exported USD 1.2 million worth of orders under EXW terms last year,and successfully obtained CNY 132,000 tax refund (tax refund rate 11%) with the help of Zhongshen in document audit.

Comparison Table of Export Tax Refund Conditions Under EXW and FOB

IV.Practical Suggestions for Enterprises: Do This First Before Choosing EXW

Director Han suggested that before signing an EXW export contract,enterprises must first contact the agent to confirm whether the customs of the target market requires a "goods departure confirmation letter",which is a new requirement in some European countries in 2026,to avoid tax refund failure due to lack of documents.At the same time,sort out the goods description on the VAT invoice in advance to ensure full consistency with the subsequent customs declaration form and bill of lading,so as to reduce the time for review and rework.