What core qualifications and business compliance requirements must be met for export tax refund processing?

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I am the person in charge of a foreign trade factory in Shanghai focusing on outdoor camping equipment. Last month, we just signed an annual order for 1,200 sets of awnings with a European client.

We used to adopt bill purchase export to simplify procedures before, and this order is worth nearly RMB 1 million. We want to switch to formal export to obtain tax refunds and cut costs, but I have gotten more confused after staying up late to look up relevant information recently: some sources claim that self-operated import and export rights are mandatory, while others say the process can be handled through an agent; some say foreign exchange must be collected within 90 days after customs declaration, while others claim the period is 180 days.

I am even more worried that our previous bill purchase export records will affect the current tax refund application, so I feel very anxious. I want to know exactly what practical conditions need to be met for export tax refund processing to avoid pitfalls and order delays.

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Expert Q&A

Linda Gao
Linda GaoYears of service:7Customer Rating:5.0

Documentation SupervisorStart a Chat

First,complete pre-qualification verification: if an enterprise handles tax refund independently,it shall hold valid self-operated import and export right filings and have export tax refund qualification indicated on its tax registration certificate,if entrusting an agent to handle tax refund,it shall ensure that the agency holds valid export tax refund agency qualification filings with customs and tax authorities,and both parties shall sign a formal agency tax refund agreement to clarify the division of rights and responsibilities.

Second,meet core transaction compliance requirements: the goods must actually depart from the country and complete export customs declaration,the commodities shall be included in the *Catalogue of Export Tax Refund (Exemption) Goods* issued by the State Administration of Taxation,the transaction shall be authentic and comply with the "four-stream consistency" principle -- core information (product name,quantity,amount) on the contract,special value-added tax invoice,customs declaration form and foreign exchange receipt and payment vouchers shall be fully matched,and false transactions or capital repatriation are strictly prohibited.

Third,meet mandatory requirements for documents and foreign exchange collection: special customs declaration form for export tax refund,special VAT input invoice (which shall be checked and certified and shall not be used to offset domestic tax) and sales subsidiary ledger for exported goods shall be retained,foreign exchange collection shall be completed within 180 days after export customs declaration. For special circumstances such as overdue payment by overseas clients,an application for foreign exchange collection extension filing shall be submitted to the tax authority in advance.

Finally,prepare exception response plans: if there is an error in customs declaration information,an application for deletion and re-declaration shall be submitted within 30 days after the issuance of the customs declaration form,if documents are lost,an application for reissuing supporting documents shall be submitted to the corresponding authority in time,if receiving a tax inquiry,authentic transaction vouchers shall be provided in cooperation to avoid suspension of tax refund qualification due to failed inspection.

Reference: Latest Guide: Imported Medical Device Online Verification Process
Grace Wang
Grace WangYears of service:10Customer Rating:5.0

Senior Foreign Trade ConsultantStart a Chat

Customs declaration forms for export tax refund shall be filled in strictly in accordance with customs specifications: the commodity code shall fully match the actual goods, the free on board (FOB) price shall be accurately calculated (after deducting overseas expenses such as freight and insurance premiums), and the "special for export tax refund" mark shall be checked on the customs declaration form. If there are differences in product name and quantity between customs declaration information and the VAT invoice, an application for deletion and re-declaration shall be submitted within 30 days after export, otherwise the tax authority will determine the declaration as invalid and directly reject the tax refund application.

In addition, under the integrated customs clearance mode, customs declaration data shall be synchronized to the tax system in real time. If data transmission is delayed, contact the customs and tax authorities for coordination in time to avoid missing the tax refund declaration deadline.

Michael Zhang
Michael ZhangYears of service:6Customer Rating:5.0

Customs Declaration & Compliance ExpertStart a Chat

Actual departure of goods from the country is the core prerequisite for export tax refund. It shall be ensured that the loading port and departure time indicated on the bill of lading are consistent with those on the customs declaration form.

If the departure of goods is delayed due to container rolling or overbooking, report to the tax authority in time and update the departure information on the customs declaration form. In addition, the original bill of lading or a copy of the telex release bill of lading shall be retained as transport documents.

In case of port change, return of goods and other circumstances, the *Proof of Tax Paid (No Tax Refund) for Returned Export Goods* shall be submitted within 15 days, otherwise it will be determined that the goods have not been actually exported and cannot enjoy the tax refund policy. At the same time, pay attention to the arrangement of free detention period to avoid inspection delay caused by goods detention at the port, which affects the timely acquisition of tax refund documents.

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

Key Account ManagerStart a Chat

The VAT input tax corresponding to export tax refund must be from authentic and compliant input invoices. Falsely issued or proxy issued invoices shall not be used.

If the VAT deferral mode is adopted for export to EU countries, ensure that the goods information of overseas VAT declaration is consistent with that of domestic export tax refund declaration to avoid the risk of double taxation. In addition, the pricing of related party transactions shall comply with the arm's length principle.

If the transaction price deviates from the market fair value by more than 20%, the tax authority will launch an anti-tax avoidance investigation, suspend the tax refund qualification and require the payment of back taxes. For enterprises without import and export rights, they can handle tax refund by entrusting a qualified agency, without applying for import and export rights on their own, but they need to ensure that the tax credit rating of the agency is Grade A or Grade B.

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

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

Export foreign exchange collection shall be completed through formal cross-border payment channels (such as SWIFT, CIPS). Illegal foreign exchange collection through personal accounts or offshore accounts is prohibited. The amount of foreign exchange collected shall be consistent with the FOB price on the customs declaration form.

If there are deductions such as commissions and discounts, they shall be clearly agreed in the contract and corresponding supporting documents shall be provided. In addition, note "export goods foreign exchange collection" in the bank remarks when settling foreign exchange.

If there is a slight difference between the amount of foreign exchange collected and the customs declaration form due to exchange rate fluctuations, provide an exchange rate conversion explanation to avoid being judged as non-trade foreign exchange collection, which affects the tax refund application. For enterprises in pilot regions, they can enjoy foreign exchange facilitation policies, no need to submit foreign exchange collection vouchers one by one, but need to retain foreign exchange collection records for future inspection.

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

Supply Chain Management ExpertStart a Chat

The export contract shall clearly stipulate core terms such as product name, quantity, price, transport mode, payment method of the goods, and there shall be no vague clauses or soft clauses. If force majeure leads to delayed delivery of goods or delayed foreign exchange collection, retain relevant evidence (such as official announcements, customer communication records) in time and apply for tax refund extension filing with the tax authority.

In addition, if the goods involve intellectual property rights, complete the customs intellectual property protection filing in advance to avoid the goods being detained due to infringement, failing to actually leave the country, and thus being unable to enjoy the tax refund policy. The original contract or a notarized copy shall be retained as the core supporting document during tax inquiry.

Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

If the goods are subject to on-site customs inspection during export, cooperate with the customs to provide authentic goods samples and document documents. If the inspection result is consistent with the customs declaration information, require the customs to affix the "inspection passed" seal on the customs declaration form; if the inspection result is inconsistent with the customs declaration form, adjust the customs declaration information in time and re-declare, otherwise it will be judged as invalid declaration and cannot handle tax refund.

In addition, check the authenticity of the container seal. If the seal is damaged or inconsistent with the seal number on the customs declaration form, contact the logistics party to verify the situation and retain evidence in time to avoid doubts about the authenticity of the transaction caused by the replacement of goods, which affects the tax refund application.

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

Director of Import & Export OperationsStart a Chat

If the exported goods are dangerous goods (such as camping gas tanks), they shall comply with UN dangerous goods packaging standards, and provide certified MSDS reports and dangerous goods packaging performance inspection result sheets, otherwise they cannot complete customs declaration and actual departure, and thus cannot enjoy the tax refund policy. For fragile goods or precision equipment, adopt buffer packaging that meets transport requirements to avoid damage to goods during transportation.

If the damaged goods need to be returned, submit the return certificate in time and pay back the refunded tax, otherwise they will be included in the tax abnormality list and the tax refund qualification will be suspended. In addition, the shipping mark on the package shall be consistent with the shipping mark on the customs declaration form to avoid inspection delay caused by inconsistent shipping marks.

Evelyn Li
Evelyn LiYears of service:3Customer Rating:5.0

Cross-border Compliance SupervisorStart a Chat

Export tax refund shall strictly abide by the "four-stream consistency" principle: core information (product name, quantity, amount, transaction subject) of contract flow, invoice flow, goods flow and capital flow shall be fully matched. If there is capital repatriation (such as transferring the funds back to the overseas client's account after receiving foreign exchange), explain the situation to the tax authority in time and provide relevant supporting documents, otherwise it will be judged as a false transaction, facing tax refund recovery, fines and even criminal liability.

In addition, documents shall be retained for 5 years for future inspection, including customs declaration forms, VAT invoices, foreign exchange collection vouchers, contracts, etc. If documents are lost, apply to the corresponding authority for reissuing certificates in time, otherwise they cannot pass the tax inspection.

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

Trade Risk Control ManagerStart a Chat

Trade terms have a direct impact on the declared amount of export tax refund: for FOB terms, the FOB price shall be taken as the tax refund declaration base; for CIF terms, tax refund shall be declared after deducting overseas expenses such as freight, insurance premiums and commissions; for EXW terms, ensure that the goods have actually left the country and completed customs declaration, otherwise they cannot enjoy the tax refund policy. In addition, supply chain inventory management shall ensure that the quantity of goods out of the warehouse is consistent with the quantity on the customs declaration form.

If there is a discrepancy between the accounts and the actual goods, adjust the inventory ledger in time and explain the reason to the tax authority to avoid failing the tax inspection due to abnormal inventory. For enterprises with annual export volume exceeding RMB 5 million, they can apply for paperless tax refund declaration to shorten the tax refund arrival time.

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