What are the core conditions for applying for export tax refund for goods exported to domestic bonded zones?

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I am the person in charge of a small electromechanical foreign trade processing factory in Shanghai. Last month, I just shipped a batch of precision accessories worth 820,000 yuan to the cooperative transit warehouse in Waigaoqiao Free Trade Zone. I originally thought I could apply for tax refund the same way as direct exports to Europe and the United States, but when the finance staff submitted the application to the tax bureau last week, it was directly rejected on the grounds of not meeting the tax refund conditions.

Now the factory is rushing to fulfill new orders, and we still owe suppliers for raw materials. This tax refund of about 110,000 yuan is literally a lifesaver for us, and I am so anxious that I cannot sleep. I would like to ask whether goods exported to the bonded zone are eligible for tax refund at all?

Is it mandatory that the goods actually depart the country? My batch of goods is still in the bonded zone warehouse now, is there any remedy to get the tax refund? Please explain the details clearly to me, otherwise I really can't hold on.

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Expert Q&A

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

Supply Chain Management ExpertStart a Chat

Not all goods exported to bonded zones are eligible for direct tax refund. The core prerequisite is the goods must actually depart the country,while meeting the requirements of document compliance and closed process loop.

In the pre-document review stage,three types of documents shall be confirmed with priority: First,the export customs declaration must be marked with "departure export" label,and the trade mode shall correspond to "general trade export" or processing trade mode that meets tax refund requirements,Second,provide the goods departure release certificate issued by the bonded zone warehouse,as well as the picking voucher of overseas customers,Third,export invoices and packing lists must be completely consistent with the information on the customs declaration,and no deviations in product name,quantity and amount are allowed.

For core node connection,after the goods are delivered to the bonded zone,you shall entrust a customs broker to handle the "exit filing declaration" within 7 working days,and simultaneously coordinate the freight forwarder to arrange the transshipment of goods to the exit port,to ensure that the customs declaration status is updated to "cleared,departed",If the goods are temporarily stored in the bonded zone,the warehouse inventory ledger shall be updated monthly to avoid being listed as a key verification target by the tax bureau due to overdue non-departure.

For your batch of goods still in the bonded zone,the contingency plan is as follows: First,directly resell to overseas customers,arrange the goods to depart from the bonded zone,and resubmit the tax refund application after supplementing the departure documents,Second,transfer the goods to special supervision zones that can directly handle tax refunds such as export processing zones,and submit the tax refund application after completing the filing. Finally,you need to ensure the consistency of the four streams,and cooperate with the tax bureau to complete the document verification to achieve compliance implementation.

Reference: Export Tax Guide: VAT, Customs Duties & Corporate Tax
Cindy Chen
Cindy ChenYears of service:3Customer Rating:5.0

Key Account ManagerStart a Chat

When declaring customs for goods exported to bonded zones, the trade mode code shall be selected accurately: If the purpose is to obtain tax refund, select "general trade export (0110)" or "processing with imported materials export (0615)", and strictly prohibit selecting "bonded zone warehousing and entrepot goods (0139)", otherwise the customs declaration will be marked as "not departed", and the tax refund review process cannot be triggered. In addition, the "exit port" on the customs declaration shall be filled with the actual exit port code instead of the bonded zone customs code; If the goods depart after transshipment in the bonded zone, mark "bonded zone transshipment departure" and the transit warehouse number in the remarks column of the customs declaration to avoid being judged as domestic circulation during document review.

If you have incorrectly declared the trade mode, apply for deleting the declaration and re-declare before the customs declaration is cleared. If the clearance date has passed, you need to submit a situation explanation and departure certificate to apply for the customs to modify the customs declaration information, otherwise the tax refund process cannot be initiated.

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

Trade Solutions ManagerStart a Chat

For goods exported to bonded zones that require tax refund, the logistics path shall be planned as "factory - bonded zone transit warehouse - exit port - overseas". You shall confirm the exit qualification of the bonded zone warehouse in advance, and give priority to warehouses with "direct exit customs declaration" qualification, which can reduce time loss in the transshipment link.

After the goods are stored in the bonded zone, arrange departure transportation within the free storage period (usually 14 days). If you need to extend the free storage period, apply to the warehouse 7 days in advance and submit the picking guarantee letter of the overseas customer to avoid container detention fees and storage fees. In addition, ensure that the "shipper" on the bill of lading is the foreign trade enterprise applying for tax refund, and the "consignee" is the overseas customer.

It is strictly prohibited to fill in the consignee of the bill of lading as the bonded zone warehouse, otherwise it will be regarded as domestic goods circulation, and it cannot be proved that the goods have actually departed. If the container is rolled over during the transshipment process, promptly issue the "special certificate for bonded zone departure tax refund" to the shipping company, and apply for priority vessel allocation to ensure that the departure time does not affect the tax refund declaration period.

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

Trade Risk Control ManagerStart a Chat

If goods exported to bonded zones have not actually departed, you can apply for the VAT deferral policy to suspend the payment of domestic VAT, and then apply for tax refund after the goods actually depart, to avoid advance capital occupation. If you are a processing trade enterprise, you can optimize tax costs through the "one-day trip in bonded zone" mode: delivering finished products to the bonded zone is regarded as export, and after applying for tax refund, you can import from the bonded zone to enjoy the processing trade bonded policy, reducing the VAT cost of raw material procurement.

Note that bonded zone trade between affiliated enterprises shall comply with the arm's length principle, and the transaction price shall be consistent with the market fair price, to avoid the tax authority judging that the affiliated transaction transfers profits, leading to the rejection of tax refund applications. In addition, enterprises shall establish a cross-border tax ledger to record the entry and exit time, transaction price and departure certificate of goods in the bonded zone, for the convenience of tax authority verification.

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

Documentation SupervisorStart a Chat

For goods exported to bonded zones with tax refund applications, the collection and payment of foreign exchange shall comply with the principle of "whoever exports collects the foreign exchange". The payment from overseas customers shall be directly paid to the domestic foreign exchange account of the foreign trade enterprise applying for tax refund, and transit through bonded zone accounts or offshore accounts is strictly prohibited. When collecting foreign exchange, the "transaction remark" in the SWIFT message shall be marked with "payment for goods exported to bonded zone" and the customs declaration number, to facilitate the bank to verify the authenticity of foreign exchange collection.

If the goods are sold to multiple overseas customers after transshipment in the bonded zone, each foreign exchange collection shall correspond to the corresponding customs declaration, to avoid the mismatch between foreign exchange collection and customs declaration, leading to the tax refund application being listed as abnormal. In addition, enterprises shall complete the foreign exchange settlement and account balancing within 30 days after receiving foreign exchange, and archive the foreign exchange collection certificate together with export documents. If there is overdue foreign exchange collection, submit the deferred payment guarantee letter of the overseas customer to the tax bureau, explain the reason and promise to collect foreign exchange within the specified period, otherwise the tax refund application will be suspended.

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

Customs Declaration & Compliance ExpertStart a Chat

For goods exported to bonded zones and applying for tax refund, a clear trade contract shall be signed. The contract shall stipulate that "the seller can apply for export tax refund only after the goods actually depart the country", and at the same time clarify the buyer's picking obligation and departure time node, to avoid the goods failing to depart in time due to the buyer's delayed picking, which affects the tax refund application.

If the ownership of the goods is transferred during the temporary storage period in the bonded zone, a goods ownership transfer agreement shall be signed, and a transfer filing application shall be submitted to the bonded zone customs to ensure the compliance of the ownership transfer, and avoid invalid tax refund documents caused by ownership disputes. In addition, enterprises shall require overseas customers to issue a picking guarantee letter, promising to arrange departure transportation within 15 days after the goods are stored in the bonded zone.

If the goods are overdue and not departed due to the buyer's reasons, the buyer shall bear the storage fees and losses caused by tax refund delay. If there is a legal dispute, you can file a lawsuit in the court with documents such as trade contracts, picking guarantee letters and customs declarations to safeguard your legitimate rights and interests.

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

Senior Operations ConsultantStart a Chat

For goods exported to bonded zones that require tax refund, you shall cooperate with the inspection personnel to confirm the authenticity and departure attribute of the goods during on-site customs inspection. During inspection, provide the detailed packing list of the goods and the order contract of the overseas customer to prove that the final flow of the goods is overseas. If the goods are required to be unpacked for inspection, coordinate with the warehouse to arrange unpacking operations in advance to ensure that the product name, quantity and specification of the goods are consistent with the customs declaration; If the goods are found to have damaged packaging or unclear labels, replace the packaging in time and re-paste the labels that meet the requirements, to avoid the customs declaration being unable to be cleared due to unqualified inspection.

In addition, confirm that the seal of the bonded zone warehouse is a unified standard seal of the customs, and it is strictly prohibited to use self-made seals of the warehouse, otherwise the inspection personnel will judge that the goods may be replaced, and cannot issue the departure release certificate. If there is an abnormality during inspection, submit the situation explanation and supplementary materials to the customs in time, and strive to complete the inspection and rectification within 3 working days to ensure the normal clearance of the customs declaration.

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

Cross-border Compliance SupervisorStart a Chat

For goods exported to bonded zones that require tax refund, the packaging shall meet the compliance requirements for exit transportation, to avoid the goods being unable to depart due to unqualified packaging, which affects the tax refund application. For ordinary goods, the packaging shall have moisture-proof and anti-seismic performance, and the outer packaging shall be marked with clear product name, quantity, destination and shipping mark, to ensure consistency with the customs declaration information; For dangerous goods, provide dangerous goods packaging that meets UN standards, attach the MSDS report, and paste the corresponding danger mark and UN number on the packaging, otherwise the bonded zone warehouse will refuse to accept the goods, or the customs will not issue the departure release certificate.

In addition, if the goods are fragile products or precision instruments, use buffer packaging materials, and mark such labels as "fragile" and "handle with care" on the packaging, to avoid damage during transportation, leading to rejection by overseas customers and failure of the goods to depart. Enterprises shall complete the packaging inspection before the goods leave the factory to ensure that the packaging meets the exit requirements, and avoid delaying the departure time due to packaging problems during transshipment in the bonded zone.

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

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

When applying for tax refund for goods exported to bonded zones, ensure the "consistency of four streams", that is, the contract stream, capital stream, goods stream and invoice stream are completely matched. During tax refund audit, the tax bureau will focus on verifying the consistency of the goods departure certificate, foreign exchange collection certificate and customs declaration. If inconsistency of the four streams is found, the tax letter adjustment process will be initiated, requiring enterprises to supplement relevant supporting materials.

If the enterprise has capital return, that is, the payment is transited through domestic accounts, the tax bureau will judge that the tax refund application has risks, and suspend the tax refund approval. In addition, enterprises shall complete the document filing within 10 days after submitting the tax refund application. The filing materials include export contracts, customs declarations, departure certificates, foreign exchange collection certificates and warehouse delivery orders, and the filing period is 5 years.

If the filing materials cannot be provided during the tax bureau's verification, the refunded tax will be recovered and late fee will be charged. For your batch of goods that have not departed, you need to resubmit the tax refund application after supplementing the departure certificate, and cooperate with the tax bureau to complete the letter adjustment to ensure the consistency of the four streams, then you can pass the audit.

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

Senior Foreign Trade ConsultantStart a Chat

For goods exported to bonded zones that require tax refund, the supply chain structure shall be planned as a full link mode of "domestic production - bonded zone transshipment - overseas sales". You shall measure the balance between tax refund cost and capital occupation cost in advance.

Enterprises can establish an inventory linkage strategy for bonded zone transit warehouses, and arrange the departure time of goods according to the order situation of overseas customers, to avoid long-term detention of goods in the bonded zone, which affects tax refund applications and increases storage costs. In addition, compare the cost difference between "direct export" and "bonded zone transit export", including logistics cost, storage cost and capital cost caused by tax refund time difference, to select the optimal export path.

If you are a large foreign trade enterprise, you can set up a branch in the bonded zone to be responsible for goods transshipment and departure operations, optimize the connection of supply chain nodes, and improve the efficiency of tax refund applications. At the same time, establish a cost actuarial model to monitor the tax refund progress and capital return situation in real time, to ensure the capital liquidity of the supply chain and reduce operational risks.

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