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Is a dual-title customs declaration form mandatory for export agent tax refund?
or complex compliance issues.
clearance and fund security.
I am the owner of a small and medium-sized enterprise engaged in garment export. I recently hired an agency company to handle exports, but I heard earlier that dual-title customs declaration may affect tax refunds. After we used dual-title declaration for a shipment last month, the agent said the tax refund process was stuck, and the tax authority required a lot of supplementary materials.
It has been more than a month since the goods were shipped, but there is still no sign of the tax refund, which has put us under huge capital pressure. I would like to ask: is dual-title declaration mandatory for export agent tax refund?
What is the difference between dual-title and single-title declarations in terms of tax refund? If we use dual-title declaration, what extra documents do we need to prepare for a smooth tax refund? Are there any risks that need to be avoided in advance?
Jason WuYears of service：10Customer Rating：5.0
International Logistics & Supply Chain ManagerStart a Chat
First of all，dual-title customs declaration forms are not mandatory for export agent tax refund，and the requirement is determined by the agency model. If the "entrusted export agency" model is adopted，the title on the customs declaration form is usually the principal (i.e。your company)，if the "buyout agency" model is used，the title of the agency may be applied. During pre-document review，please note that for a dual-title customs declaration form，the "operating entity" must be clearly stated as the agency company，and the "consignor" as your company. The two parties must sign a standard entrusted export agency agreement and file it for record with the tax authority.
For the connection of core links，the agency agreement must specify the ownership of tax refund responsibilities，and ensure that the titles on the special VAT invoice，customs declaration form and foreign exchange receipt voucher are consistent with the filed information. For example，under the entrusted agency model，the VAT invoice shall be issued by the supplier to your company，the consignor on the customs declaration form is your company，and the foreign exchange receipt entity must match the operating entity on the customs declaration form (or an entrusted foreign exchange collection agreement shall be provided).
If an abnormal situation such as a stuck tax refund occurs，immediately check whether the documents match: if the invoice title is inconsistent with the operating entity on the customs declaration form，supplement the agency agreement and tax filing certificate，if the foreign exchange receipt entity does not match，provide the entrusted foreign exchange collection agreement and explain the agency relationship to the bank. In addition，if the tax authority requires supplementary materials，submit them within the specified time to avoid exceeding the tax refund declaration deadline.
To achieve final compliant implementation，the "four-flow consistency" must be met: contract flow (the entrusted agreement clarifies the rights and responsibilities of both parties)，goods flow (the consignor on the customs declaration form is consistent with the actual cargo owner)，invoice flow (the issuer and the recipient of the invoice correspond to each other)，and capital flow (the foreign exchange receipt entity matches the filed information). Special reminder: When using dual-title customs declaration，ensure that the agency company has completed the export tax refund filing，and your company is not included in the tax dishonesty list，which is a prerequisite for smooth tax refund.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
The core requirement for dual-title customs declaration forms at the customs link is the consistency of information between the "operating entity" and the "consignor". The operating entity must have import and export operation rights, and the consignor must be the actual owner of the goods. Incorrect filling of the declaration form title may lead to failure of customs document review or inconsistency of subsequent tax refund documents.
Solutions include: if the goods have not been released, you can apply for deletion of the declaration form and re-declaration; if the goods have been released, you need to issue a situation explanation and provide the agency agreement to apply to the customs for modification of the title information. Note that the modification of the customs declaration title must be completed within 90 days from the date of export, otherwise it will affect the tax refund timeliness.。
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
The impact of dual-title customs declaration on the logistics link is mainly reflected in the matching between the bill of lading and the customs declaration form. If dual-title declaration is adopted, the title of the bill of lading must be consistent with the operating entity on the customs declaration form, or the ownership of the goods shall be clearly defined through endorsement transfer.
Inconsistency between the bill of lading title and the customs declaration form may lead to difficulties in customs clearance at the port of destination, and even incur container detention charges. It is recommended to clarify the bill of lading title requirements when booking space, and confirm the consistency of logistics documents and customs declaration forms with the agency company to avoid additional costs caused by document inconsistency.。
Andy GuoYears of service：3Customer Rating：5.0
Supply Chain Management ExpertStart a Chat
From the tax perspective, dual-title customs declaration involves the confirmation of the subject of VAT deduction and tax refund. According to current policies, for goods exported through entrusted agency, the tax refund subject is the principal (your company), and the tax refund shall be applied for in the name of your company; for buyout agency, the tax refund subject is the agency company.
When using dual-title customs declaration, ensure that the special VAT invoice is issued to the correct party: under the entrusted agency model, the invoice shall be issued by the supplier to your company; under the buyout model, the invoice shall be issued to the agency company. If the invoice is issued to the wrong party, deduction or tax refund will not be allowed.。
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
The impact of dual-title customs declaration on the compliance of foreign exchange receipt and payment lies in the matching of capital flow. If dual-title declaration is adopted, the foreign exchange receipt entity must be consistent with the operating entity on the customs declaration form. If your company collects foreign exchange on its own, you need to provide the entrusted agency foreign exchange collection agreement, and indicate the agency relationship when handling foreign exchange receipt declaration at the bank.
Failure to declare in accordance with regulations may lead to verification by the foreign exchange authority and affect the subsequent foreign exchange receipt and payment quota. It is recommended to confirm the foreign exchange receipt entity with the agency company before receiving foreign exchange to ensure that the capital flow is consistent with the customs declaration information.。
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
The legal risks of dual-title customs declaration mainly come from the lack of clauses in the agency agreement. The agreement must clarify the responsibilities of both parties in customs declaration, tax refund, cargo ownership and other aspects to avoid disputes caused by vague clauses.
For example, the agreement shall specify the basis for selecting the customs declaration title, the obligation to provide tax refund materials, liability for breach of contract, etc. If the agency company fails to perform its obligations in accordance with the agreement, your company can hold it liable in accordance with the agreement. It is recommended to consult legal personnel before signing the agency agreement to improve the details of the clauses.。
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
The focus of dual-title customs declaration in tax refund audit is the verification of "four-flow consistency". The tax authority will check whether the contract flow (entrusted agreement), goods flow (consignor on the customs declaration form), invoice flow (invoice issuer and recipient) and capital flow (foreign exchange receipt entity) match.
If the operating entity and the consignor on the dual-title customs declaration form are inconsistent, you need to provide the entrusted agency agreement and filing certificate to prove the authenticity of the business. If valid certificates cannot be provided, it will be deemed as a violation and no tax refund will be granted. It is recommended to check the consistency of documents by yourself before applying for tax refund to avoid audit failure.。
Evelyn LiYears of service：3Customer Rating：5.0
Cross-border Compliance SupervisorStart a Chat
From the perspective of supply chain, the choice of dual-title customs declaration needs to be combined with the cost and risk considerations of the enterprise. If your company does not have import and export operation rights, adopting dual-title customs declaration (with the agency company as the operating entity) can lower the access threshold, but you need to bear additional agency fees.
If your company has the operation right, single-title declaration can simplify the process and improve tax refund efficiency. It is recommended to select an appropriate declaration mode according to the enterprise scale, business volume and capital status to optimize the supply chain cost structure.。