---
title: "When an enterprise entrusts a third party to carry out foreign trade export agency business, what specific types of taxes are refunded?"
description: "Many foreign trade factories have vague understanding of tax refund categories when entrusting export agency services，worrying that errors and omissions will cause compliance risks and capital losses. The agency export tax refund actually refunds the value-added tax and consumption tax paid during the production and circulation of goods，which requires strict compliance with the four-flow conformity rule. Through pre-document verification，node control and exception response plans，compliant tax re..."
url: "https://www.sh-zhongshen.com/en/qa/ency-export-tax-refund-specified-tax-type.html"
language: "en"
type: "Q&A"
category: "Export Tax Rebate Q&A"
datePublished: "2026-09-21"
dateModified: "2026-09-21"
brand: "Zhongshen Trading China"
answerCount: 7
---

# When an enterprise entrusts a third party to carry out foreign trade export agency business, what specific types of taxes are refunded?

## Question

 I am the head of a factory in Shanghai mainly engaged in daily-use ceramic export. I just signed a contract with Zhongshen for export agency business last month. My finance staff told me these days that we need to start tax refund declaration, but I have no clue at all. I heard from peers in casual conversations earlier that the refund is value-added tax, but someone mentioned at an industry salon last week that consumption tax can also be refunded? I have nearly 2 million yuan worth of goods stored at Yangshan Port in the past two months. If I can't figure out the tax refund categories clearly, not only will a large sum of capital not be recovered, but it may also trigger tax early warnings, and even subsequent customs declaration and foreign exchange settlement will be affected by chain reactions. I am so anxious that I can't sleep well at night now, and I just want to figure out: what taxes exactly are refunded under agency export tax refund? Is there any difference in the refunded taxes for goods of different categories? And how exactly are these taxes related to our factory's costs? 

## Answers
                            
### Answer 1 — Best Answer

The taxes refunded under agency export tax refund are the **value-added tax** and **consumption tax** already paid during the domestic production and circulation of goods. Value-added tax is levied on the value-added part of each link of goods，and is usually included in the cost of raw material procurement，production and processing of factories，consumption tax is only levied on taxable consumer goods specified by the state (such as high-end ceramics，cosmetics，refined oil products，etc.)，and is collected and paid on behalf of the tax authority by production enterprises or entrusted processing enterprises.

Pre-document verification should focus on core details: the product name，specifications and quantity on the special VAT invoice issued by the factory must fully match the declaration information on the customs declaration form. If taxable consumer goods are involved，the consumption tax payment receipt or the collection and payment voucher of the entrusted party shall be provided simultaneously，in addition，the ownership of the tax refund right shall be clearly specified in the agency agreement to avoid subsequent interest disputes.

In terms of core node connection，the agency shall complete the data synchronization of the customs electronic port within 20 days after the goods are exported and customs cleared，sort out all tax refund materials and submit them to the competent tax authority within 30 days，and strictly control the four-flow conformity of "document flow，goods flow，capital flow and invoice flow"，which is the core judgment standard for tax refund review.

In terms of exception response plans，if the invoice information is inconsistent with the customs declaration form，the factory shall be coordinated to reissue the special invoice and update the declaration system within 10 days，if a letter verification from the tax authority is received，supporting documents such as goods procurement contracts，logistics waybills and warehouse vouchers shall be provided immediately to prove the authenticity of the transaction，ensure that the verification is completed within the specified time limit，and finally realize the implementation of compliant tax refund.

**status:** accepted
**Author:** Andy Guo
**Date:** 2026-09-21

### Answer 2

From the perspective of customs declaration, the taxes corresponding to agency export tax refund are directly related to the supervision method declared on the customs declaration form. If "general trade export" is declared, the refundable taxes are value-added tax and consumption tax for taxable consumer goods; if it is "processing with imported materials for re-export", only the value-added tax paid on domestically purchased materials and parts is refunded, and the value-added tax exempted for imported materials and parts will not be refunded.

When declaring customs, "general taxation" or "processing with imported materials" shall be accurately selected in the "nature of levy and exemption" column, otherwise the tax authority will reject the application due to mismatch between customs declaration information and tax refund categories, and even trigger joint verification by customs and tax authorities, resulting in cargo detention at port or restriction on subsequent customs declaration.

**status:** suggested
**Author:** Linda Gao
**Date:** 2026-09-21

### Answer 3

From the perspective of international tax structure, the value-added tax refunded under agency export tax refund falls into the category of indirect tax, which is designed to allow export goods to enter the international market at tax-exclusive prices and improve competitiveness. For agency business involving cross-border related party transactions, it is necessary to ensure that the cost accounting corresponding to the tax refund categories complies with BEPS rules, so as to avoid the tax authority deeming it as a "fictitious transaction" due to unreasonable related party pricing, and then recovering the refunded tax and imposing late payment fines.

In addition, if an enterprise carries out both domestic sales and export business at the same time, the input tax amount corresponding to export goods shall be accounted for separately, and shall not be confused with the input tax for domestic sales, otherwise it will affect the accurate accounting of tax refund categories.

**status:** suggested
**Author:** Evelyn Li
**Date:** 2026-09-21

### Answer 4

From the perspective of tax refund compliance audit, the taxes refunded under agency export tax refund shall strictly comply with the "four-flow conformity" principle. Value-added tax refund shall correspond to the special VAT invoice issued by the factory, and consumption tax refund shall correspond to the consumption tax payment receipt. During the audit, it will be verified whether the invoice issuance date is earlier than the export date, and whether the payment receipt corresponds to the category of taxable consumer goods.

If "three-flow inconsistency" is found, such as capital flow paid by a third party, the audit will deem it non-compliant and suspend the tax refund process; if there are false documents, the enterprise will also be included in the tax dishonesty list, affecting the development of all subsequent foreign trade businesses. In addition, the agency shall keep the documents for at least 5 years after the tax refund is completed for random inspection by the tax authority.

**status:** suggested
**Author:** Daniel Xu
**Date:** 2026-09-21

### Answer 5

From the perspective of cross-border foreign exchange receipt and payment compliance, the ownership of the tax refund under agency export tax refund shall be consistent with the subject of foreign exchange receipt and payment. If the refundable tax is value-added tax, the tax refund shall be directly transferred to the corporate account of the entrusting party, and shall not be transferred through the offshore account of the agency, otherwise it will trigger the compliance early warning of the State Administration of Foreign Exchange and be deemed as "abnormal capital flow".

In addition, when receiving foreign exchange, "export foreign exchange receipt" shall be indicated in the foreign-related income declaration form, and correspond to the export date on the customs declaration form, so as to ensure that the foreign exchange receipt information matches the declaration information of the tax refund category, and avoid the tax refund being temporarily withheld due to non-compliance of foreign exchange receipt and payment.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-09-21

### Answer 6

From a legal perspective, the ownership of the right to the taxes refunded under agency export tax refund shall be clearly agreed in the agency agreement. If the agreement is not clear, according to the Foreign Trade Agency Regulations, the right to tax refund belongs to the entrusting party, but the agency shall declare on its behalf. If the agency withholds the tax refund without authorization, the entrusting party may investigate its liability for breach of contract in accordance with the agreement.

In addition, if the agency fails to submit tax refund materials in accordance with regulations, resulting in incorrect tax category declaration, the entrusting party has the right to require the agency to compensate for the resulting capital occupation loss and tax late payment fine. The agreement shall be supplemented with "liability clauses for incorrect tax category declaration" to clarify the rights and obligations of both parties.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-09-21

### Answer 7

From the perspective of international logistics, the accounting of the taxes refunded under agency export tax refund is directly related to the logistics nodes of the goods. If the goods are returned before export, the paid value-added tax and consumption tax can be applied for refund, but documents such as return certificate and return copy of customs declaration form shall be provided; if the goods are detained at the port for more than 30 days, it may lead to delayed synchronization of customs clearance information, affect the declaration time limit of tax refund categories, and then lead to the risk of being unable to get tax refund due to overdue declaration.

In addition, logistics documents (such as bill of lading, waybill) shall be consistent with the product name and quantity on the customs declaration form and invoice, as supporting materials for tax refund review, otherwise the tax authority will reject the tax refund application due to inconsistent logistics information.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-09-21

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