---
title: "Under the export tax refund agency cooperation model, who shall bear the international logistics freight?"
description: "Many export enterprises often get involved in disputes and even delay the tax refund progress when cooperating with agencies to handle tax refunds，due to unclear definition of the freight bearing party. The freight bearing party is mainly determined according to trade terms and contract agreements. Under FOB terms，the overseas buyer is generally responsible for the freight，while under CIF terms，the exporter shall be responsible. If the agency pays the freight on behalf，explicit recovery clauses..."
url: "https://www.sh-zhongshen.com/en/qa/export-tax-refund-agency-shipping-freight-bearing-party-clarification.html"
language: "en"
type: "Q&A"
category: "Export Tax Rebate Q&A"
datePublished: "2026-09-14"
dateModified: "2026-09-14"
brand: "Zhongshen Trading China"
answerCount: 8
---

# Under the export tax refund agency cooperation model, who shall bear the international logistics freight?

## Question

 I am the head of a women's wear export enterprise in Shanghai. I just signed an export tax refund agency agreement with Zhongshen last week, and now I am preparing a batch of women's wear worth 800,000 RMB to be shipped to Hamburg, Germany. When we discussed the cooperation earlier, we defaulted to adopt FOB Shanghai terms. I thought your agency would be responsible for the domestic freight to the port, but the account manager in charge of the cooperation told me yesterday that we need to pay this part of the freight ourselves, and added that the international freight is borne by the overseas customer. However, I vaguely remember that peers said some agencies will cover part of the freight. Now this part of rights and responsibilities is not clearly written in the contract, I am particularly worried that there will be hidden freight we need to bear later, and even more afraid that the issue of freight bearing party will affect the subsequent tax refund declaration -- after all, the tax refund amount of this batch of goods is crucial for us to ease the cash flow pressure. I am very anxious now and want to figure out as soon as possible which freight should be paid by us, and which is the responsibility of the agency or the customer? 

## Answers
                            
### Answer 1 — Best Answer

In traditional export tax refund agency cooperation，many enterprises often fall into the dilemmas of "no way to recover the advance freight paid by the agency" and "freight cost overrun" because they do not clearly specify the freight bearing party in the contract. Even worse，unclear ownership of freight vouchers leads to failure to match compliant documents during tax refund declaration，triggering tax inquiry correspondence，delaying tax refund arrival，and occupying the enterprise's cash flow.

The optimization path shall be combined with trade terms and contract agreements: if FOB terms are adopted，the domestic pre-port freight is generally borne by the export enterprise，and the international freight is borne by the overseas buyer，if CIF terms are adopted，the full-range freight is borne by the export enterprise，which can entrust the agency to pay on behalf，but the **advance payment period and recovery clauses** shall be clearly specified in the contract. Meanwhile，the VAT deferment policy can be used to include the value-added tax corresponding to the freight into the deferment scope，so as to reduce short-term capital pressure.

The only requirement is to attach a separate detailed list of freight rights and responsibilities when signing the agency agreement，clarifying the bearing party of each transport section，document provision requirements and tax refund matching rules. Following this operation can reduce the risk of freight disputes to zero，ensure the compliance of tax refund declaration documents，shorten the tax refund arrival time by 3-5 working days，and increase the cash flow turnover rate by about 15%.

**status:** accepted
**Author:** Lucas Liu
**Date:** 2026-09-14

### Answer 2

From the perspective of customs valuation and customs declaration compliance, the clarification of the freight bearing party directly affects the filling accuracy of the freight column on the customs declaration form. If customs declaration is made under FOB terms, the international freight amount shall be filled in the freight column of the customs declaration form. If it is actually borne by the overseas buyer, it shall be noted in the remarks column of the customs declaration form that "freight is paid by overseas buyer"; if CIF terms are adopted, the actual paid full-range freight amount shall be filled in the freight column, and corresponding documents such as freight invoices and bills of lading shall be provided.

If the freight bearing party is not accurately filled in during customs declaration, it may trigger customs valuation query, require the enterprise to supplement freight payment vouchers, and even lead to the return of the customs declaration form, affecting the export timeliness of goods. In addition, if the agency pays the freight on behalf, it shall ensure that the freight payer on the customs declaration form is consistent with the actual capital flow, so as to avoid customs verification caused by "inconsistency of three flows (capital flow, document flow, goods flow)".

**status:** suggested
**Author:** Cindy Chen
**Date:** 2026-09-14

### Answer 3

From the perspective of international logistics operation, the selection of freight bearing party directly affects the connection efficiency of logistics nodes. If it is agreed that the overseas buyer shall bear the international freight, the information of the freight forwarder designated by the buyer shall be confirmed in advance to ensure that the domestic goods are delivered to the designated warehouse on time, so as to avoid container rolling and space overbooking caused by untimely communication with the freight forwarder; if the export enterprise bears the full-range freight, it can entrust the agency to integrate logistics resources, select direct routes to shorten transportation time, and negotiate with the logistics provider on the extension clause of free storage period to reduce the risk of container detention fees.

If the freight bearing party is not clearly specified in the contract, the logistics provider may refuse to release the goods because no one pays the freight, resulting in cargo detention at the port, high port detention fees and container detention fees, and even the risk of goods being auctioned. In addition, it should be noted that the freight payment clause on the bill of lading shall be consistent with the contract agreement, so as to avoid disputes during the subsequent endorsement and transfer of the bill of lading.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-09-14

### Answer 4

From the perspective of international tax planning, the selection of freight bearing party will affect the tax cost of enterprises. If the export enterprise bears the freight, the freight expenditure can be included in cost accounting and deducted before enterprise income tax. Meanwhile, if eligible, the VAT input tax corresponding to the freight can be deducted; if the VAT deferment policy is adopted, the import VAT corresponding to the freight (for destination port customs clearance freight) can be paid on a deferred basis, so as to reduce short-term capital pressure.

If the agency pays the freight on behalf, it shall ensure that the title of the freight invoice issued by the agency is the export enterprise, and the invoice content is consistent with the actual transportation service, so as to avoid failure to deduct input tax due to non-compliant invoices. In addition, if the overseas buyer bears the freight, the freight factor shall be considered in cross-border related transaction pricing, so as to avoid BEPS-related tax risks caused by unreasonable pricing.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-09-14

### Answer 5

From the perspective of cross-border foreign exchange receipt and payment compliance, the clarification of the freight bearing party directly affects the accuracy and compliance of foreign exchange receipt and payment. If the export enterprise bears the freight, it shall pay the freight through compliant channels to ensure that the capital flow is consistent with the logistics and document flow, so as to avoid being listed as a concerned object by the State Administration of Foreign Exchange due to "inconsistency of three flows"; if the overseas buyer bears the international freight, it shall clearly distinguish the payment for goods and freight when receiving foreign exchange, so as to avoid including the freight into the total foreign exchange received for goods, resulting in inconsistency between the received foreign exchange amount and the amount on the customs declaration form and triggering foreign exchange verification.

If the agency pays the freight on behalf, it shall note "advanced export freight" when making foreign exchange payment, and keep documents such as the advance payment agreement and freight invoice for future reference, so as to avoid the State Administration of Foreign Exchange questioning the compliance of fund use. In addition, if RMB cross-border payment (CIPS) is adopted, it shall ensure that the message information of freight payment is consistent with the contract agreement, so as to avoid payment being returned.

**status:** suggested
**Author:** Evelyn Li
**Date:** 2026-09-14

### Answer 6

From the perspective of international trade law, the agreement on the freight bearing party is one of the core clauses of the agency agreement. If it is not clearly agreed, subsequent disputes will be judged in accordance with INCOTERMS® 2020, but courts in different regions may have different interpretations of the terms, which increases the difficulty of dispute resolution. Therefore, it is necessary to clearly stipulate the freight bearing party, payment time, document requirements and liability for breach of contract for each transport section in the agency agreement.

If the agency pays the freight on behalf, the interest calculation method, recovery period and dispute resolution method for the advance payment shall be agreed. In addition, if logistics delay is caused by the failure of the freight bearing party to pay the freight in time, the corresponding liability for breach of contract shall be clearly defined, so as to avoid being unable to investigate the responsibility due to unclear agreement and causing losses to the enterprise. At the same time, it should be noted that the freight payment clause on the bill of lading shall be consistent with the agreement in the agency agreement, so as to avoid conflicts between the bill of lading clauses and the contract clauses.

**status:** suggested
**Author:** Jason Wu
**Date:** 2026-09-14

### Answer 7

From the perspective of export tax refund compliance audit, the clarification of the freight bearing party directly affects the compliance of tax refund declaration. During tax refund audit, the tax authority will verify the "consistency of four flows", namely the consistency of capital flow, logistics flow, document flow and contract flow. If the freight bearing party is inconsistent with the contract agreement and the content filled in the customs declaration form, it may trigger tax inquiry correspondence, require the enterprise to supplement documents such as freight payment vouchers and advance payment agreement, and even lead to the rejection of tax refund due to inconsistent documents.

If the agency pays the freight on behalf, it shall ensure that the agency has actually paid the freight and provide documents such as bank payment receipts and freight invoices. At the same time, it shall accurately fill in the freight amount and bearing party in the tax refund declaration system, so as to avoid the failure of tax refund review due to filling errors. In addition, freight-related documents shall be filed together with tax refund declaration documents, and the retention period shall be no less than 5 years for the inspection of tax authorities.

**status:** suggested
**Author:** Andy Guo
**Date:** 2026-09-14

### Answer 8

From the perspective of supply chain planning, the selection of freight bearing party will affect the supply chain cost and efficiency of enterprises. If the export enterprise bears the full-range freight, it can reduce the unit freight cost by integrating logistics resources and purchasing logistics services in bulk.

At the same time, it can optimize the inventory layout, deliver the goods to the port warehouse in advance, and shorten the stocking time; if the overseas buyer bears the international freight, it can reduce the capital occupation pressure of the enterprise, but it is necessary to maintain close communication with the buyer to ensure the synchronization of logistics information, so as to avoid logistics delay caused by the low efficiency of the buyer's freight forwarder. In addition, the appropriate freight bearing mode shall be selected in combination with the enterprise's tax refund cycle and cash flow status.

If the enterprise has tight cash flow, it can choose the overseas buyer to bear the international freight, or entrust the agency to pay on behalf and agree on a longer recovery period, so as to ease the short-term capital pressure. At the same time, it is necessary to regularly evaluate the cost-effectiveness of the freight bearing mode and adjust the supply chain strategy in time.

**status:** suggested
**Author:** Linda Gao
**Date:** 2026-09-14

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