---
title: "Does the Received Export Tax Refund Need to Pay Enterprise Income Tax? - Zhongshen Trading China"
description: "In 2026，the foreign trade industry continues to recover. Many Shanghai-based foreign trade enterprises have confusion about whether the tax refund needs to be taxed again after completing export tax refund procedures. In response to this core question，Supervisor Long from Zhongshen pointed out that the tax payment of export tax refund needs to be judged based on the actual business scenario of the enterprise，not all cases require additional tax，and specific attention should be paid to the connec..."
url: "https://www.sh-zhongshen.com/en/news/export-tax-refund-need-pay-enterprise-income-tax.html"
language: "en"
type: "Article"
category: "Industry News"
datePublished: "2026-08-14"
dateModified: "2026-08-14"
brand: "Zhongshen Trading China"
image: "https://cndpic.sh-zhongshen.com/uploads/tradepics/forex/ss0OpkjpbBwTj.webp"
---

# Does the Received Export Tax Refund Need to Pay Enterprise Income Tax?

## Is Export Tax Refund Taxable?A Cost and Tax Guide Must-Read for Shanghai Foreign Trade Enterprises

When many owners of Shanghai foreign trade enterprises ask agency companies to handle export tax refund,the first question they ask is "how are the fees calculated",and many people wonder after getting the refund: "Does this returned money need to pay other taxes?" In 2026,the foreign trade industry continues to recover,and many enterprises are worried about additional tax costs incurred after the tax refund arrives.Today,combined with the practical experience of Supervisor Long from Zhongshen,we will clarify the cost structure related to export tax refund and the tax issues of tax refund to help you avoid pitfalls.

![Export Tax Refund and Tax Payment: Clarify 3 Key Questions to Avoid Losses](https://cndpic.sh-zhongshen.com/uploads/tradepics/forex/ss0OpkjpbBwTj.webp)

## I.Core Cost Structure of Export Tax Refund Services in 2026

The fee for export tax refund agency service is not one-size-fits-all,it is mainly divided into three categories,each with different reasons for occurrence and billing methods:

### 1.Basic Agency Service Fee (Core Charge Item)

**Reason for Occurrence**: It covers the labor cost of agency companies for sorting tax refund declaration materials,operating tax bureau systems,following up on tax coordination and other labor services.After the popularization of electronic declaration in 2026,labor costs have decreased slightly,but professional review still requires dedicated personnel.

**Billing Method**:

- Percentage of tax refund amount: 0.8%-1.2% for general trade,0.5%-0.9% for processing with imported materials (as processing with imported materials requires manual verification,the process is more complex);
- Per order charging: RMB 500-800 per order for cross-border e-commerce retail export (Mode 9610),which is suitable for small-batch,high-frequency orders;
- Package charging: For large clients with annual tax refund exceeding RMB 5 million,the service can be packaged at "annual service fee of RMB 20,000-50,000",covering the whole year’s tax refund declaration service.

**Negotiable**: Yes!For example,a Shanghai-based mechanical and electrical enterprise with an annual tax refund of RMB 8 million negotiated with Zhongshen,and the service fee ratio decreased from 1.0% to 0.7%,saving about RMB 24,000 in annual cost.

### 2.Declaration-related Administrative Fees (Most Have Been Canceled)

**Reason for Occurrence**: Starting from 2025,the Shanghai Tax Bureau has fully implemented electronic declaration,and administrative fees such as printing and mailing of paper materials have been basically canceled,only a few remote areas may have sporadic fees.

![Avoid the Pit! Is the Export Tax Refund Actually Taxable?](https://cndpic.sh-zhongshen.com/uploads/tradepics/DCOZ4UBKNN2bD.webp)

**Billing Method**: Charged based on actual occurrence (if any).In 2026,more than 90% of agency companies have included it in the service fee package,and do not charge separately.

**Negotiable**: No room for negotiation,it is a fixed cost after policy adjustment.

### 3.Possible Tax Cost of Tax Refund (Key Focus)

**Reason for Occurrence**: Whether the tax refund needs to pay enterprise income tax depends on the type of tax refund and the deduction of input tax,which is clearly stipulated in Document No.12 of the Ministry of Finance in 2026.

**Billing Method**: The tax refund part in the taxable income is calculated according to the enterprise income tax rate,20% for small and micro enterprises,25% for general enterprises.

**Negotiable**: Stipulated by policy,no room for negotiation,requires advance calculation.

## II.Comparison of Costs and Taxes Under Different Trade Modes (2026)

Different trade modes have different export tax refund procedures,and there are also differences in cost structure and tax payment of tax refund.The following is the comparison table sorted by Supervisor Long from Zhongshen:

| Trade Mode | Agency Service Fee (2026) | Declaration Administrative Fee | Is Tax Refund Subject to Income Tax | Remarks (Shanghai Region) |
| --- | --- | --- | --- | --- |
| General Trade (Mechanical and Electrical Products) | 0.8%-1.2% (based on tax refund amount) | None (Electronic Declaration) | Partially taxable (taxable if input tax has been deducted as cost) | Required to provide special VAT invoice,tax refund rate 13% |
| Processing with Imported Materials (Textiles) | 0.5%-0.9% (based on tax refund amount) | None | Not required (duty-free imported materials) | Requires verification of processing with imported materials manual,verification cycle shortened to 10 days in 2026 |
| Cross-border E-commerce Retail Export (Mode 9610) | CNY 500-800 per order | None | Not required (ticket-free tax exemption policy) | Required to register as an enterprise in Shanghai Cross-border E-commerce Comprehensive Pilot Zone,the scope of the pilot zone expanded to 5 districts including Pudong and Songjiang in 2026 |
| Cross-border E-commerce B2B Export (Mode 9710) | 0.6%-1.0% (based on tax refund amount) | None | Partially taxable (same as general trade) | Required to provide export customs declaration and VAT invoice,declaration process simplified by 30% in 2026 |

## III.Differences in Tax Payment of Tax Refund Under Different Scenarios

Whether the tax refund is taxable depends on the core point: "whether the tax refund belongs to the taxable income of the enterprise".The following is the judgment for common scenarios:

- **Scenario 1: General trade export of goods (input tax has been deducted as cost)** A Shanghai-based electronics enterprise exported CNY 1.5 million worth of goods from January to June 2026,with input tax of CNY 195,000,tax refund rate of 13%,and tax refund of CNY 195,000.Since this input tax has been deducted as cost when calculating enterprise income tax,the tax refund needs to be included in taxable income,and CNY 48,750 of income tax is paid at 25% rate.
- **Scenario 2: Re-export after processing with imported materials (duty-free imported materials)** A garment enterprise imported CNY 800,000 of raw materials (duty-free),exported CNY 2 million worth of finished goods after processing,tax refund rate 13%,tax refund = (200×13%) - (80×13%) = CNY 156,000.Since imported materials are duty-free,the tax refund does not involve enterprise income tax,no additional tax is required.
- **Scenario 3: Cross-border e-commerce retail export (9610 ticket-free tax exemption)** A Shanghai-based cross-border e-commerce enterprise exported CNY 5 million worth of goods via Mode 9610 in 2026,chose the ticket-free tax exemption policy and did not apply for tax refund,so there is no tax refund and no income tax is required; if it chooses declaration with invoice,the tax refund needs to be judged according to the rules of general trade.

## IV.Beware of Hidden Charge Traps in Export Tax Refund Services

In 2026,there are still a few agency companies with hidden charges in the Shanghai market.Supervisor Long from Zhongshen reminds to pay attention to the following 3 points:

- **Ambiguous content included in service fee**: For example,they advertise "0 service fee" but charge "urgent tax refund fee" (CNY 200-500 per order) and "document review fee" (CNY 100-300 per time) separately.Formal companies like Zhongshen only charge urgent fee for requests of arrival within 3 days,and clarify it in advance.
- **Charge even if tax refund fails**: A few small agency companies still charge CNY 300-500 "service fee" even if the tax refund is not successful,while Zhongshen promises "charge only after successful tax refund,no charge if failed".
- **Non-transparent tax calculation**: They do not inform the proportion of income tax that needs to be paid for the tax refund in advance,resulting in a reduction of the actual funds received by the enterprise.For example,a client paid CNY 20,000 more income tax because the previous agency did not remind,and only clarified the policy after communicating with Supervisor Long later.

## V.Tax Refund Suggestions for Shanghai Foreign Trade Enterprises in 2026

Combined with the policy changes in 2026,Supervisor Long from Zhongshen gives 3 practical suggestions:

- **Calculate tax cost in advance**: Before signing the agency agreement,ask the agency to help calculate the amount of income tax on the tax refund,to avoid subsequent cost overrun.For example,a small and micro enterprise with annual tax refund of CNY 1 million needs to reserve CNY 20,000 in advance if income tax is required.
- **Choose an agency with transparent charging**: Prioritize companies with clear service fees and no hidden charges.For example,the charging standard of Zhongshen can be checked on the official website,and the customer satisfaction of cooperating clients reached 98% in 2026.
- **Keep complete business documents**: The sampling inspection rate of export tax refund by the tax bureau reached 15% in 2026,so it is necessary to keep input invoices,export customs declarations,logistics documents and other materials,to avoid affecting the tax refund due to incomplete documents.

For Shanghai foreign trade enterprises handling export tax refund,choosing the right agency company can save a lot of trouble.Zhongshen has been deeply engaged in the industry for more than 20 years,and has provided export agency and tax refund services for more than 300 Shanghai enterprises in 2026.Supervisor Long’s team can provide free tax calculation for tax refund.If you need to know the specific fees,you can contact the staff of Zhongshen for consultation.

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