What Conditions Can Export Enterprises Meet to Apply for Export Tax Refund in 2026?

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  • Aug 22, 2026 at 06:40
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I am the owner of a small and medium-sized enterprise engaged in women's clothing export. Recently I have encountered several very tricky tax refund-related problems. Last month, I entrusted a foreign trade company to handle agency export of a batch of dresses to Europe, and the agent said the shipment may not meet the tax refund conditions, which I have never encountered before.

In addition, we just launched cross-border e-commerce retail export this year, selling goods through third-party platforms, and we are not sure whether we can apply for tax refund. Besides, for an earlier order of re-export after processing with supplied materials, our finance team said it may not be eligible for refund, but I heard from peers that some such orders are eligible, so I am quite confused now.

The quarterly declaration is coming soon, and if these problems are not solved, it will affect our capital turnover. I want to know what specific scenarios are eligible for export tax refund, especially for enterprises like me that have agency export, cross-border e-commerce and processing with supplied materials businesses, which scenarios meet the requirements?

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Andy Guo
Andy GuoYears of service：3Customer Rating：5.0

Supply Chain Management ExpertStart a Chat

The core conditions for export tax refund in 2026 are mainly centered on three dimensions: "real export of goods，complete and compliant documents，and fulfilled tax obligation". Specific requirements vary for different business types:

First，for general trade export business，it is required to meet: goods have been declared and departed from the territory via customs，special value-added tax (VAT) invoices have been issued and corresponding taxes have been paid，foreign exchange collection has been completed (except for special cases)，and all required documents are filed (such as customs declaration form，bill of lading，contract，etc.). Goods for Entrusted Agency Export require the entrusting party and the agent to sign a formal agency agreement，the agent assists in providing documents such as the customs declaration form，and the entrusting party applies for tax refund as the tax refund subject. The "consistency of four flows" (contract flow，goods flow，capital flow，invoice flow) must be guaranteed.

Second，for cross-border e-commerce retail export business，the 2026 policy clearly supports eligible enterprises to apply for tax refund: enterprises need to declare customs via China Customs cross-border e-commerce supervision codes (such as 9610，9710)，confirm real export of goods，obtain legal and valid purchase certificates (such as special VAT invoices)，and complete foreign exchange collection. Under 9610 Mode，enterprises need to file on the cross-border e-commerce comprehensive service platform to ensure that order，logistics and customs declaration data are traceable.

Third，for re-export business of processing with supplied materials，traditional processing with supplied materials is usually not eligible for tax refund because raw materials come from abroad and no domestic VAT is paid，however，if it is converted to processing with imported materials (raw materials are purchased by the enterprise and VAT is paid)，tax refund can be applied for in accordance with regulations. In addition，enterprises should note the declaration deadline: generally，tax refund declaration must be completed within 90 days from the date of export (can be extended for special cases). It is recommended that enterprises regularly reconcile information between customs declaration forms and invoices to ensure data consistency and avoid tax refund failure caused by information errors.

Reference: Compliance Checklist for Importing Spanish Wine as an Agent: Avoid the 3 Hidden Traps That 90% of Experienced Traders Fall Into
Evelyn Li
Evelyn LiYears of service：3Customer Rating：5.0

Cross-border Compliance SupervisorStart a Chat

In export tax refund audit, the core inspection is the "consistency of four flows": contract flow shall clarify the rights and obligations of both buyer and seller, goods flow shall match the information on the customs declaration form (such as product name, quantity, specification), capital flow requires the collected foreign exchange amount to be consistent with the customs declared amount (±5% error is allowed), and invoice flow requires the product name and quantity on the special VAT invoice to be fully consistent with the customs declaration form.

If an enterprise has entrusted agency export, it needs to provide the original agency agreement and the customs declaration power of attorney from the agent, and the agent must mark "agency export" on the customs declaration form. For cross-border e-commerce business, it is necessary to verify the correlation between platform order information, logistics tracking number and customs declaration form to ensure data traceability.

Kevin Lin
Kevin LinYears of service：4Customer Rating：5.0

Trade Solutions ManagerStart a Chat

The impact of customs declaration process on tax refund mainly lies in the accuracy of customs declaration information. Enterprises need to ensure that the "trade mode" on the customs declaration form is filled in correctly: general trade shall be filled with "0110", cross-border e-commerce retail export shall be filled with "9610" or "9710", and entrusted agency export shall be filled with "1010" (general trade agency).

Incorrect trade mode filling will directly lead to rejection of tax refund application. In addition, the "domestic source of goods" on the customs declaration form must be consistent with the location of the invoice issuer, otherwise the tax authority may require a letter verification, which will delay the tax refund process.

Jason Wu
Jason WuYears of service：10Customer Rating：5.0

International Logistics & Supply Chain ManagerStart a Chat

From the tax perspective, the premise of export tax refund is that the enterprise has paid the corresponding VAT. For re-export of processing with imported materials, enterprises can choose the "exemption, credit and refund" policy: when calculating the non-exemptable and non-deductible tax amount, it is calculated by multiplying the FOB price of current export goods by the exchange rate, then multiplying by the difference between the tax rate and refund rate; if the enterprise chooses the tax exemption policy, no VAT is required, but no tax refund can be applied for either.

If cross-border e-commerce enterprises meet the requirements (such as registered in the comprehensive pilot zone, exported via the platform, obtained legal certificates), they can enjoy the "tax exemption without invoice" policy, but they need to file relevant order and logistics information.

Grace Wang
Grace WangYears of service：10Customer Rating：5.0

Senior Foreign Trade ConsultantStart a Chat

Compliant foreign exchange collection is a necessary condition for tax refund. Enterprises need to complete foreign exchange collection within 180 days from the date of export (extension can be applied for special cases such as pandemic), and the collected amount shall be consistent with the customs declared amount (reasonable error is allowed).

For enterprises using CIPS for cross-border RMB payment, it is necessary to ensure that the transaction code on the foreign exchange collection certificate is "121010" (general trade export foreign exchange collection), and the customs declaration number is marked in the remark column. If an enterprise collects foreign exchange via an offshore account, it needs to provide the bank statement of the offshore account and the corresponding export contract to prove the legality of the fund source.

Victor Sun
Victor SunYears of service：5Customer Rating：5.0

Trade Risk Control ManagerStart a Chat

From the legal perspective, export tax refund requires that contract terms meet regulatory requirements. The entrusted agency export contract must clearly stipulate that the tax refund subject is the entrusting party, and the agent undertakes the obligation to assist in providing documents; unclear stipulation in the contract may lead to disputes over the tax refund subject.

For cross-border e-commerce business, the agreement signed with the platform must include the clause of "assisting in providing export-related documents" for tax authority verification. In addition, enterprises must ensure that the goods have no intellectual property infringement. If infringement is found by customs, the enterprise will lose the tax refund qualification.

Cindy Chen
Cindy ChenYears of service：3Customer Rating：5.0

Key Account ManagerStart a Chat

The key impact of logistics link on tax refund lies in the completeness of transport documents. Enterprises need to keep the original bill of lading (sea freight) or air waybill (air freight), and the consignee and destination on the document must be consistent with the customs declaration form.

For cross-border e-commerce retail export, enterprises need to provide logistics tracking numbers (such as EMS, DHL tracking numbers), and ensure that the logistics information can show the overseas signing record. If logistics documents are missing or information does not match, the tax authority may reject the tax refund application. It is recommended that enterprises choose formal logistics service providers to ensure complete documents and accurate information.

Eric Zhou
Eric ZhouYears of service：6Customer Rating：5.0

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

If on-site inspection finds that goods do not match the information on the customs declaration form, it will affect tax refund. For example, if the actual product name does not match the declaration, or there is a quantity difference, customs will issue an inspection record, and the tax authority will reject the tax refund application based on the record.

Enterprises shall cooperate with customs to provide relevant supporting materials (such as contracts, invoices, packing lists) during inspection. If the inspection result is "consistent", the original inspection record shall be kept for tax refund procedures. In addition, the shipping mark on the goods packaging must be consistent with the shipping mark on the customs declaration form to avoid abnormal inspection caused by inconsistent shipping marks.

Daniel Xu
Daniel XuYears of service：10Customer Rating：5.0

Director of Import & Export OperationsStart a Chat

In supply chain planning, enterprises need to optimize tax refund related process nodes. For example, for entrusted agency export business, enterprises shall select qualified agency companies and clarify tax refund responsibilities in advance; for cross-border e-commerce business, enterprises can integrate logistics and customs declaration resources, and adopt the "list clearance, summary declaration" mode of the comprehensive pilot zone to simplify the tax refund process.

In addition, enterprises can adjust the trade mode (such as converting processing with supplied materials to processing with imported materials) to enjoy the tax refund policy and improve capital turnover rate. It is recommended that enterprises regularly evaluate tax refund risk points in the supply chain and optimize processes to improve tax refund efficiency.

Note: We respect all users' expressions; however, user comments represent their personal views only.

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