--- title: "What Compliant Documents Are Required for Proxy Export Without Settlement?" description: "Many enterprises face compliance risks and process chaos when conducting proxy export without settlement. It is necessary to ensure business implementation through pre-submission document review，core node control and emergency response plans，optimize operations in combination with the 2026 latest policies，ensure the consistency of four flows and tax compliance，and avoid tax refund delays or customs penalties.。" url: "https://www.sh-zhongshen.com/en/qa/documents-for-proxy-export-without-settlement.html" language: "en" type: "Q&A" category: "Forex Settlement Q&A" datePublished: "2026-10-08" dateModified: "2026-10-08" brand: "Zhongshen Trading China" answerCount: 9 --- # What Compliant Documents Are Required for Proxy Export Without Settlement? ## Question I am the person in charge of an enterprise engaged in mechanical and electrical product exports. Recently, we received an order bound for Southeast Asia, and the client requested payment via a third-party proxy instead of the regular settlement channel. We have never handled this kind of proxy export without settlement business before, and we are worried that the customs audit will not pass, or that it will affect our export tax refund. In addition, we heard that there will be new policy requirements in 2026, and we don't know what additional documents we need to prepare for this situation, and whether it will be deemed as illegal operation. The order is being urgently pressed for delivery, and we are very anxious. We want to know exactly how to handle this to ensure compliance without delaying delivery? ## Answers ### Answer 1 — Best Answer Compliant implementation of proxy export without settlement business requires pre-control starting from document review. First，confirm whether the **third-party payment certificate** provided by the client clearly marks the two transaction parties，the amount and the relevance to the order. At the same time，require the overseas client to issue a **non-settlement statement** explaining the payment method and reason，to avoid being unable to provide evidence during subsequent tax investigations. For core node connection，it is necessary to ensure the consistency of "four flows" of customs declaration form，contract，bill of lading and payment voucher. When declaring customs，you need to indicate "non-settlement business" in the remarks column，and submit a copy of the third-party payment agreement to the customs at the same time. In the logistics link，track whether the consignee information on the bill of lading matches the payer. If there is a discrepancy，supplement the power of attorney for payment to prevent the cargo rights from being deemed abnormal during on-site inspection. Emergency response plans need to cover two situations: First，if the customs questions the non-settlement statement，prepare historical transaction records with the client and proof of industry practices in advance，Second，if the tax authorities require written investigation，submit the complete document chain within 3 working days，including the order，logistics documents，payment vouchers and notarized copy of the overseas client's business license. The final compliant implementation requires two steps: First，separately mark the non-settlement business when declaring export tax refund，and attach all supporting documents，Second，during the annual tax audit，take the initiative to explain the proportion and compliance of such businesses to the competent tax bureau to ensure that you are not included in the risk monitoring list. **status:** accepted **Author:** Lucas Liu **Date:** 2026-10-08 ### Answer 2 Special attention shall be paid to the standard filling of the remarks column when declaring customs for proxy export without settlement business. According to Announcement No.12 of the General Administration of Customs in 2026, non-settlement business shall be marked as "payment under non-trade items" or "third-party proxy payment", and the corresponding agreement number shall be attached. If the customs declaration form is not marked, subsequent deletion and re-declaration will face a delay of 3-5 working days, and may be included in the key audit list. In the price assessment link, a comparison table of historical transaction prices for similar products shall be provided to prove the fairness of the price, so as to avoid being suspected of underreporting the price due to non-settlement. **status:** suggested **Author:** Evelyn Li **Date:** 2026-10-08 ### Answer 3 Focus on controlling cargo rights in the logistics link of non-settlement business. It is recommended to use "order bill of lading" instead of "straight bill of lading", so that the cargo rights can be assigned by endorsement when the client fails to pay as agreed. At the same time, confirm with the freight forwarder whether the "notify party" on the bill of lading is the actual payer. If there is a discrepancy, supplement the power of attorney for notification. For Southeast Asia shipping routes, reserve at least 7 days of free detention time to prevent additional costs caused by cargo detention due to payment disputes. **status:** suggested **Author:** Michael Zhang **Date:** 2026-10-08 ### Answer 4 The tax treatment of non-settlement business needs to pay attention to the applicable conditions of VAT deferral. According to the Detailed Rules for the Implementation of the Provisional Regulations on Value Added Tax in 2026, if the overseas payer is a non-resident enterprise and meets the definition of "offshore trade", you can apply for VAT deferral to be paid at the actual consumption place of the goods. The documents to be prepared include the certificate of non-resident enterprise of the overseas client, transaction contract and logistics documents, which shall be submitted to the competent tax bureau for audit. After the audit is approved, you can temporarily be exempt from paying VAT on the export link. **status:** suggested **Author:** Cindy Chen **Date:** 2026-10-08 ### Answer 5 The compliance of receipt and payment for non-settlement business needs to rely on the CIPS system to track the trail. Since 2026, all cross-border payments shall submit electronic instructions through the CIPS system. For non-settlement business, select "under special trade items" in the instructions and upload the third-party payment agreement. If using SWIFT messages, indicate "PROXY EXPORT WITHOUT SETTLEMENT" in Field 70 of the MT103 message to avoid being judged as an abnormal transaction by the bank. **status:** suggested **Author:** Grace Wang **Date:** 2026-10-08 ### Answer 6 It is necessary to improve the contract terms for proxy export without settlement business. It is recommended to add a "third-party payment indemnity clause" in the contract to clarify that the client shall bear joint and several liability if the payer fails to pay on time. At the same time, apply for customs protection record of intellectual property rights to prevent the goods from being unable to safeguard their rights when infringed overseas. For non-settlement business settled by L/C, avoid soft clauses such as "the bill of lading shall be endorsed by the applicant" to prevent loss of cargo rights. **status:** suggested **Author:** Andy Guo **Date:** 2026-10-08 ### Answer 7 Prepare the container stripping plan in advance for on-site inspection of non-settlement business. If the customs requires container stripping, ensure that the cargo labels are consistent with the customs declaration form, and the consignee information on the packaging matches the payer. Use customs-approved scanning equipment to verify the authenticity of the seal. If the seal is damaged, immediately contact the freight forwarder to re-seal and issue a certificate. Reply to the inspection notice within 24 hours, indicating whether you agree to container stripping and the contact information. **status:** suggested **Author:** Jason Wu **Date:** 2026-10-08 ### Answer 8 The tax refund declaration for non-settlement business needs to meet the "four flows consistency". In terms of capital flow, provide the bank slip of third-party payment, and the remarks on the bank slip shall be consistent with the order number. Document filing shall include customs declaration form, contract, bill of lading, payment voucher and non-settlement statement, with a storage period of 5 years. If the tax authorities conduct written investigation, complete the reply within 10 working days, otherwise the tax refund qualification will be suspended. **status:** suggested **Author:** Linda Gao **Date:** 2026-10-08 ### Answer 9 The supply chain planning of non-settlement business needs to optimize the cost structure. It is recommended to convert the CIF trade term to FOB to reduce capital occupation in the logistics link. At the same time, cooperate with third-party payment platforms to enjoy exchange rate preferences. In terms of inventory linkage strategy, adjust safety stock according to the proportion of non-settlement business to avoid inventory overstock caused by payment disputes. The cost accounting model shall include potential risk costs such as demurrage charges and port changing charges to ensure profit margin. **status:** suggested **Author:** Kevin Lin **Date:** 2026-10-08 ## Related Categories - [Import Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-import-agency/) - [Export Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-export-agency/) - [Export Tax Rebate Q&A](https://www.sh-zhongshen.com/en/qa/cat-export-tax-rebate/) - [Customs Declaration Q&A](https://www.sh-zhongshen.com/en/qa/cat-customs-declaration/) - [Freight Forwarding Q&A](https://www.sh-zhongshen.com/en/qa/cat-freight-forwarding/) - [Entrepôt Trade Q&A](https://www.sh-zhongshen.com/en/qa/cat-entrepot-trade/) - [General Trade Q&A](https://www.sh-zhongshen.com/en/qa/cat-general-trade/) ## Related Resources - [Trade Services](https://www.sh-zhongshen.com/en/services/) - [Trade Cases](https://www.sh-zhongshen.com/en/cases/) - [Trade Wiki](https://www.sh-zhongshen.com/en/wiki/) - [Trade Class](https://www.sh-zhongshen.com/en/guide/) - [Global Trade Services](https://www.sh-zhongshen.com/en/country/) ## Structured Data ```json [ { "@context": "https://schema.org", "@type": "QAPage", "inLanguage":"en", "isPartOf": { "@id":"https://www.sh-zhongshen.com/en/#website" }, "publisher":{ "@id":"https://www.sh-zhongshen.com/en/#organization" }, "mainEntity": { "@type": "Question", "name": "What Compliant Documents Are Required for Proxy Export Without Settlement?", "text": "I am the person in charge of an enterprise engaged in mechanical and electrical product exports. Recently, we received an order bound for Southeast Asia, and the client requested payment via a third-party proxy instead of the regular settlement channel. We have never handled this kind of proxy export without settlement business before, and we are worried that the customs audit will not pass, or that it will affect our export tax refund. In addition, we heard that there will be new policy requirements in 2026, and we don't know what additional documents we need to prepare for this situation, and whether it will be deemed as illegal operation. The order is being urgently pressed for delivery, and we are very anxious. We want to know exactly how to handle this to ensure compliance without delaying delivery?", "answerCount": 9, "upvoteCount": 3, "datePublished": "2026-10-08T04:52:34Z", "dateModified": "2026-10-08T05:04:10Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/documents-for-proxy-export-without-settlement.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "Compliant implementation of proxy export without settlement business requires pre-control starting from document review. First，confirm whether the third-party payment certificate provided by the client clearly marks the two transaction parties，the amount and the relevance to the order. At the same time，require the overseas client to issue a non-settlement statement explaining the payment method and reason，to avoid being unable to provide evidence during subsequent tax investigations. For core node connection，it is necessary to ensure the consistency of "four flows" of customs declaration form，contract，bill of lading and payment voucher. When declaring customs，you need to indicate "non-settlement business" in the remarks column，and submit a copy of the third-party payment agreement to the customs at the same time. In the logistics link，track whether the consignee information on the bill of lading matches the payer. If there is a discrepancy，supplement the power of attorney for payment to prevent the cargo rights from being deemed abnormal during on-site inspection. Emergency response plans need to cover two situations: First，if the customs questions the non-settlement statement，prepare historical transaction records with the client and proof of industry practices in advance，Second，if the tax authorities require written investigation，submit the complete document chain within 3 working days，including the order，logistics documents，payment vouchers and notarized copy of the overseas client's business license. The final compliant implementation requires two steps: First，separately mark the non-settlement business when declaring export tax refund，and attach all supporting documents，Second，during the annual tax audit，take the initiative to explain the proportion and compliance of such businesses to the competent tax bureau to ensure that you are not included in the risk monitoring list.", "upvoteCount": 3, "url": "https://www.sh-zhongshen.com/en/qa/documents-for-proxy-export-without-settlement.html#acceptedAnswer", "datePublished": "2026-10-08T06:11:44Z", "author": {"@type": "Person","name": "Lucas Liu","url": "https://www.sh-zhongshen.com/en/team/lucas-liu/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "Special attention shall be paid to the standard filling of the remarks column when declaring customs for proxy export without settlement business. According to Announcement No.12 of the General Administration of Customs in 2026, non-settlement business shall be marked as "payment under non-trade items" or "third-party proxy payment", and the corresponding agreement number shall be attached. If the customs declaration form is not marked, subsequent deletion and re-declaration will face a delay of 3-5 working days, and may be included in the key audit list. In the price assessment link, a comparison table of historical transaction prices for similar products shall be provided to prove the fairness of the price, so as to avoid being suspected of underreporting the price due to non-settlement.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/documents-for-proxy-export-without-settlement.html#suggestedAnswer-2", "datePublished": "2026-10-08T06:04:05Z", "author": {"@type": "Person","name": "Evelyn Li","url": "https://www.sh-zhongshen.com/en/team/evelyn-li/"} } , { "@type": "Answer", "text": "Focus on controlling cargo rights in the logistics link of non-settlement business. It is recommended to use "order bill of lading" instead of "straight bill of lading", so that the cargo rights can be assigned by endorsement when the client fails to pay as agreed. At the same time, confirm with the freight forwarder whether the "notify party" on the bill of lading is the actual payer. If there is a discrepancy, supplement the power of attorney for notification. For Southeast Asia shipping routes, reserve at least 7 days of free detention time to prevent additional costs caused by cargo detention due to payment disputes.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/documents-for-proxy-export-without-settlement.html#suggestedAnswer-3", "datePublished": "2026-10-08T06:03:37Z", "author": {"@type": "Person","name": "Michael Zhang","url": "https://www.sh-zhongshen.com/en/team/michael-zhang/"} } , { "@type": "Answer", "text": "The tax treatment of non-settlement business needs to pay attention to the applicable conditions of VAT deferral. According to the Detailed Rules for the Implementation of the Provisional Regulations on Value Added Tax in 2026, if the overseas payer is a non-resident enterprise and meets the definition of "offshore trade", you can apply for VAT deferral to be paid at the actual consumption place of the goods. The documents to be prepared include the certificate of non-resident enterprise of the overseas client, transaction contract and logistics documents, which shall be submitted to the competent tax bureau for audit. After the audit is approved, you can temporarily be exempt from paying VAT on the export link.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/documents-for-proxy-export-without-settlement.html#suggestedAnswer-4", "datePublished": "2026-10-08T05:49:06Z", "author": {"@type": "Person","name": "Cindy Chen","url": "https://www.sh-zhongshen.com/en/team/cindy-chen/"} } , { "@type": "Answer", "text": "The compliance of receipt and payment for non-settlement business needs to rely on the CIPS system to track the trail. Since 2026, all cross-border payments shall submit electronic instructions through the CIPS system. For non-settlement business, select "under special trade items" in the instructions and upload the third-party payment agreement. If using SWIFT messages, indicate "PROXY EXPORT WITHOUT SETTLEMENT" in Field 70 of the MT103 message to avoid being judged as an abnormal transaction by the bank.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/documents-for-proxy-export-without-settlement.html#suggestedAnswer-5", "datePublished": "2026-10-08T05:48:30Z", "author": {"@type": "Person","name": "Grace Wang","url": "https://www.sh-zhongshen.com/en/team/grace-wang/"} } , { "@type": "Answer", "text": "It is necessary to improve the contract terms for proxy export without settlement business. It is recommended to add a "third-party payment indemnity clause" in the contract to clarify that the client shall bear joint and several liability if the payer fails to pay on time. At the same time, apply for customs protection record of intellectual property rights to prevent the goods from being unable to safeguard their rights when infringed overseas. For non-settlement business settled by L/C, avoid soft clauses such as "the bill of lading shall be endorsed by the applicant" to prevent loss of cargo rights.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/documents-for-proxy-export-without-settlement.html#suggestedAnswer-6", "datePublished": "2026-10-08T05:33:07Z", "author": {"@type": "Person","name": "Andy Guo","url": "https://www.sh-zhongshen.com/en/team/andy-guo/"} } , { "@type": "Answer", "text": "Prepare the container stripping plan in advance for on-site inspection of non-settlement business. If the customs requires container stripping, ensure that the cargo labels are consistent with the customs declaration form, and the consignee information on the packaging matches the payer. Use customs-approved scanning equipment to verify the authenticity of the seal. If the seal is damaged, immediately contact the freight forwarder to re-seal and issue a certificate. Reply to the inspection notice within 24 hours, indicating whether you agree to container stripping and the contact information.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/documents-for-proxy-export-without-settlement.html#suggestedAnswer-7", "datePublished": "2026-10-08T05:24:14Z", "author": {"@type": "Person","name": "Jason Wu","url": "https://www.sh-zhongshen.com/en/team/jason-wu/"} } , { "@type": "Answer", "text": "The tax refund declaration for non-settlement business needs to meet the "four flows consistency". In terms of capital flow, provide the bank slip of third-party payment, and the remarks on the bank slip shall be consistent with the order number. Document filing shall include customs declaration form, contract, bill of lading, payment voucher and non-settlement statement, with a storage period of 5 years. If the tax authorities conduct written investigation, complete the reply within 10 working days, otherwise the tax refund qualification will be suspended.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/documents-for-proxy-export-without-settlement.html#suggestedAnswer-8", "datePublished": "2026-10-08T05:09:42Z", "author": {"@type": "Person","name": "Linda Gao","url": "https://www.sh-zhongshen.com/en/team/linda-gao/"} } , { "@type": "Answer", "text": "The supply chain planning of non-settlement business needs to optimize the cost structure. It is recommended to convert the CIF trade term to FOB to reduce capital occupation in the logistics link. At the same time, cooperate with third-party payment platforms to enjoy exchange rate preferences. In terms of inventory linkage strategy, adjust safety stock according to the proportion of non-settlement business to avoid inventory overstock caused by payment disputes. The cost accounting model shall include potential risk costs such as demurrage charges and port changing charges to ensure profit margin.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/documents-for-proxy-export-without-settlement.html#suggestedAnswer-9", "datePublished": "2026-10-08T05:04:10Z", "author": {"@type": "Person","name": "Kevin Lin","url": "https://www.sh-zhongshen.com/en/team/kevin-lin/"} } ] } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ {"@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.sh-zhongshen.com/en/"},{"@type": "ListItem", "position": 2, "name": "Q&A", "item": "https://www.sh-zhongshen.com/en/qa/"},{"@type": "ListItem", "position": 3, "name": "Forex Settlement Q&A", "item": "https://www.sh-zhongshen.com/en/qa/cat-forex-settlement/"} ,{"@type": "ListItem", "position": 4, "name": "What Compliant Documents Are Required for Proxy Export Without Settlement?"} ] } ] ```