---
title: "What are the specific compliance requirements for filling in RMB FOB value in the export tax refund declaration process?"
description: "In export business settled in cross-border RMB，enterprises often encounter declaration errors，delayed tax refunds or even compliance risks due to unfamiliarity with FOB value filling rules. It is necessary to strictly match the RMB FOB value indicated on the customs declaration form，verify the consistency between settlement vouchers and contracts，and retain supporting materials for discrepancies，so as to meet tax compliance requirements，complete tax refund declaration smoothly，and avoid losses s..."
url: "https://www.sh-zhongshen.com/en/qa/compliance-requirements-for-filling-rmb-fob-value-in-export-tax-refund.html"
language: "en"
type: "Q&A"
category: "Export Tax Rebate Q&A"
datePublished: "2026-10-30"
dateModified: "2026-10-30"
brand: "Zhongshen Trading China"
answerCount: 7
---

# What are the specific compliance requirements for filling in RMB FOB value in the export tax refund declaration process?

## Question

 I am the handler of a foreign trade enterprise in Shanghai mainly engaged in the export of small and medium-sized electromechanical products. Last month, we just completed 3 general trade exports settled in cross-border RMB, with a total value of about 1.2 million RMB, which were shipped to Southeast Asia and Europe respectively. When doing the tax refund declaration for April 2026 these days, I am stuck at the step of filling in the RMB FOB value. We used to handle US dollar settlement business before, and we always converted the US dollar FOB value on the customs declaration form into RMB for filling, but this time the customs declaration form directly indicates the RMB FOB value. However, the accountant said that we also need to correspond to the amount on the bank settlement slip, and there is a difference of more than 20,000 RMB between the two amounts, which is said to be the bank deducted handling fees and transfer fees. I am afraid that incorrect filling will lead to delayed tax refund or even letter investigation by the tax bureau. I went through the latest announcement of the State Administration of Taxation yesterday but still failed to figure it out. The declaration deadline is the day after tomorrow, and I am very anxious. I would like to ask how to fill in the RMB FOB value accurately, and whether there are any details to pay attention to and pitfalls to avoid? 

## Answers
                            
### Answer 1 — Best Answer

First conduct pre-document review: it is necessary to simultaneously verify the amount information of three types of core documents，namely **customs declaration form，cross-border RMB settlement slip，and export contract**. The "RMB FOB value" field on the customs declaration form is the basis for filling. It is necessary to confirm that this amount is the sum of all costs before the goods arrive at China's customs border，excluding domestic freight，insurance premiums and customs declaration fees.

Core node connection: In the tax refund declaration system，directly fill in the RMB FOB value indicated on the customs declaration form without further conversion. If there is a difference between the settlement slip and the customs declaration amount (such as bank handling fees，transfer fees)，you need to separately retain **bank deduction vouchers，transfer service agreements** as supporting materials，and there is no need to deduct them from the FOB value，so as to avoid early warning triggered by inconsistency with the customs declaration information.

Abnormal contingency plan: If the RMB FOB value is not indicated on the customs declaration form，the actual FOB value of cross-border RMB settlement shall prevail，and at the same time apply to the customs broker for supplementing the remarks on the customs declaration form or issuing a FOB value confirmation letter，if a declaration error occurs，immediately contact the tax refund window of the competent tax bureau to submit supporting materials and explain the reason for the difference.

Final compliance implementation: After filling，verify through the pre-declaration function of the tax refund system，confirm that it is consistent with the electronic data of the customs declaration form before formal submission，and file and retain all documents for more than 5 years to ensure compliance with the 2026 cross-border RMB settlement tax refund requirements.

**status:** accepted
**Author:** Victor Sun
**Date:** 2026-10-30

### Answer 2

From the perspective of customs declaration, the filling of RMB FOB value must fully match the "transaction price (RMB)" field on the customs declaration form. This field is the FOB price verified by the customs in accordance with the Measures for the Customs to Examine and Determine the Dutiable Value of Import and Export Goods, including the value of the goods itself, transportation and insurance premiums before export (before arriving at China's customs border), and excluding domestic sundry fees.

If the FOB value filled by the enterprise in the tax refund declaration is inconsistent with the electronic data of the customs declaration form, it will trigger a joint data comparison and early warning between the customs and the tax authority, resulting in the suspension of tax refund review, requiring the enterprise to submit an application for modification of the customs declaration form or a difference explanation letter. It is recommended to clearly require the customs broker to mark the accurate RMB FOB value on the customs declaration form when declaring, so as to avoid subsequent data differences that affect the tax refund progress.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-10-30

### Answer 3

From the perspective of cross-border taxation, the filling of RMB FOB value directly affects the tax calculation base of export tax refund, and must strictly follow the provisions of the 2026 Administrative Measures for Export Tax Refund of Cross-border RMB Settlement: For export business settled in RMB, the RMB FOB value indicated on the customs declaration form is preferred for tax refund FOB value; if it is not indicated on the customs declaration form, the actual FOB value on the cross-border RMB settlement voucher shall prevail, and the amount shall not be adjusted arbitrarily for tax planning. If an enterprise falsely reports a higher FOB value in order to increase the tax refund amount, it will be identified as tax evasion by the tax authority, facing recovery of tax refund, late fees and fines, which will seriously affect the enterprise's tax credit rating and even restrict the subsequent tax refund authority.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-10-30

### Answer 4

From the perspective of cross-border receipt and payment compliance, the filling of RMB FOB value needs to form a logical closed loop with the transaction amount of the cross-border RMB settlement slip: If the settlement slip amount includes additional fees such as bank handling fees and transfer fees, the FOB value and the deduction part need to be accounted for separately.

The FOB value shall be filled with the amount indicated on the customs declaration form, and the deduction part shall be listed separately in the foreign exchange receipt details to ensure the consistency of the four streams (goods stream, capital stream, document stream, invoice stream). If the deduction part is deducted from the FOB value, the amount of the capital stream will be inconsistent with that of the document stream, triggering a compliance inspection by the State Administration of Foreign Exchange, and affecting the enterprise's subsequent cross-border RMB settlement authority and foreign exchange quota.

**status:** suggested
**Author:** Andy Guo
**Date:** 2026-10-30

### Answer 5

From the perspective of tax refund audit, the filling of RMB FOB value is one of the core verification points of tax letter investigation. In 2026, the tax authority's tax refund audit for RMB settlement export business focuses on the consistency of FOB value with customs declaration forms and settlement vouchers.

If there is a difference, the enterprise is required to provide supporting materials, including but not limited to bank deduction vouchers, supplementary agreements for export contracts, and explanations for customs declaration modification. It is recommended that enterprises establish an internal audit mechanism before tax refund declaration, and assign special personnel to review the FOB value filling data to ensure consistency with various documents, so as to avoid triggering tax letter investigation due to data inconsistency and prolonging the tax refund cycle.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-10-30

### Answer 6

From the perspective of supply chain planning, the filling of RMB FOB value needs to be linked with trade terms: If FOB RMB trade terms are adopted, the FOB value is the FOB amount indicated on the customs declaration form; if CIF RMB terms are adopted, the insurance premium and freight shall be deducted from the CIF amount before filling the FOB value.

It is recommended that enterprises clearly adopt FOB RMB terms when signing export contracts, simplify the FOB value accounting process, and avoid filling errors caused by trade term conversion. At the same time, the cost of freight and insurance premiums can be reduced by optimizing the logistics path, which indirectly increases the tax calculation base of tax refund and increases the tax refund income.

**status:** suggested
**Author:** Jason Wu
**Date:** 2026-10-30

### Answer 7

From the perspective of legal compliance, the filling of RMB FOB value must be consistent with the transaction price clause in the export contract. If the RMB FOB value agreed in the export contract is different from that in the customs declaration form and settlement voucher, a supplementary agreement shall be signed in time to clarify the reason for the difference, so as to avoid being identified as false trade.

In 2026, China has intensified its crackdown on false export tax refunds. If an enterprise is identified as false trade due to false filling of FOB value, in addition to facing tax penalties, it may also bear civil liability for breach of contract and even criminal liability. It is recommended that enterprises clarify the composition and adjustment clauses of FOB value when signing export contracts, so as to provide legal basis for subsequent tax refund filling.

**status:** suggested
**Author:** Linda Gao
**Date:** 2026-10-30

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