---
title: "Do Export Tax Refund Enterprises Need to Pay Urban Maintenance and Construction Tax and Other Additional Taxes on VAT Exemption and Offset Amount?"
description: "The finance personnel of foreign trade enterprises mainly engaged in mechanical and electrical product export are caught in a dilemma over whether to pay additional tax on VAT exemption and offset amount. They fear that underpayment will trigger tax early warning and affect the progress of export tax refund，while overpayment will aggravate cash flow pressure. It is clearly stipulated that VAT exemption and offset amount is the statutory tax base of additional tax，and compliant payment is require..."
url: "https://www.sh-zhongshen.com/en/qa/export-tax-refund-enterprises-vat-exemption-offset-amount-extra-tax-payment.html"
language: "en"
type: "Q&A"
category: "Export Tax Rebate Q&A"
datePublished: "2026-10-22"
dateModified: "2026-10-22"
brand: "Zhongshen Trading China"
answerCount: 10
---

# Do Export Tax Refund Enterprises Need to Pay Urban Maintenance and Construction Tax and Other Additional Taxes on VAT Exemption and Offset Amount?

## Question

 I am a finance personnel at a foreign trade enterprise mainly engaged in mechanical and electrical product export based in Shanghai. These days I am busy with the tax declaration for the first quarter of 2026, and I am so anxious that I even got canker sores. Last week when I had dinner with industry peers, a friend doing clothing export said that the VAT exemption and offset amount from export tax refund does not need to pay additional tax at all. But yesterday when I checked the newly updated 2026 foreign trade tax compliance guideline released by the tax bureau, it vaguely mentions that VAT exemption and offset amount belongs to the levy scope of additional tax. Now I am completely confused. Our VAT exemption and offset amount for the first quarter is nearly 800,000 RMB. If we underpay, I am afraid it will trigger tax early warning, we need to not only make up the tax but also pay late payment penalty, and even affect the review progress of subsequent export tax refund; if we declare and pay blindly, I am afraid it will waste unnecessary cost, since our company's cash flow is already tight recently. We want to confirm whether we need to pay this tax, as well as the precautions for declaration. 

## Answers
                            
### Answer 1 — Best Answer

First of all，we need to point out a common misunderstanding among foreign trade enterprises: many enterprises mistakenly believe that VAT exemption and offset amount is a part of export tax refund and does not need to pay additional tax，which is completely wrong. According to the *Interim Regulations on Urban Maintenance and Construction Tax* which is still in force in 2026 and subsequent supplementary collection and management regulations，VAT exemption and offset amount is the deduction part of an enterprise's current payable value-added tax，and is the statutory tax base for Urban Maintenance and Construction Tax，Education Fee Surcharge and Local Education Surcharge.

If payment is not made in accordance with regulations，the upgraded tax system of Golden Tax Phase IV in 2026 will compare the VAT exemption，offset and refund declaration data with additional tax declaration data in real time，and usually trigger tax early warning within 3 working days，which will further lead to supplementary tax，late payment penalty of 0.05% per day. In severe cases，it will reduce the enterprise's tax credit rating to Class B，which will not only cancel the qualification for expedited export tax refund approval，but also may list the enterprise as a key audit target for the year，affecting the customs clearance efficiency of subsequent import and export business.

In terms of risk isolation measures，before monthly declaration，enterprises should simultaneously export the **detail report of current-period VAT exemption and offset amount** from the VAT exemption，offset and refund declaration system，check it one by one against the tax base in the additional tax declaration system，and submit the declaration after confirming that all data matches completely.

Exclusive stop-loss tip: if there has been underpayment in the past，you can make voluntary supplementary payment during the **annual voluntary self-inspection period** of the tax authority in 2026，and submit a situation description affixed with the official seal. After verification by the tax authority，you can apply for exemption from late payment penalty，and it will not affect the tax credit rating assessment.

**status:** accepted
**Author:** Jason Wu
**Date:** 2026-10-22

### Answer 2

If an enterprise's tax credit rating is downgraded due to failure to pay additional tax on VAT exemption and offset amount, it will directly affect the maintenance or application of the customs advanced certified enterprise qualification. In 2026, the customs integrated clearance system has realized real-time data interconnection with the tax system. Import and export goods of enterprises with tax credit rating Class B or below will be listed as key inspection targets, the average customs clearance time will increase by 30%, and enterprises may also be required to provide additional deposit or bank guarantee before goods are released.

In addition, if an enterprise is listed as a dishonest entity due to tax issues, the customs will suspend its convenient customs clearance measures such as "advance declaration, release upon arrival of goods", the probability of goods being detained at the port will increase significantly, and the resulting port detention fee and container detention fee will further increase the enterprise's operating cost. It is recommended that enterprises check tax and customs credit data synchronously every month to ensure consistent compliance status.

**status:** suggested
**Author:** Cindy Chen
**Date:** 2026-10-22

### Answer 3

If an enterprise triggers tax early warning and is listed as a dishonest entity due to failure to pay additional tax on VAT exemption and offset amount, logistics suppliers will adjust the cooperation terms. In 2026, the international logistics industry has realized partial data sharing with the tax credit system.

Most leading shipping companies and freight forwarding enterprises will increase the booking deposit ratio for dishonest enterprises to 50% of the freight, and even refuse to accept their booking requests, forcing enterprises to choose niche logistics channels. This not only increases transportation cost by 20%-30%, but also may face risks such as container rolling and space congestion.

In addition, if goods cannot be cleared in time after arrival at the port due to enterprise dishonesty, container detention fee will be charged at 100-300 USD per day depending on the container type, and the transfer of cargo title will be restricted, which may trigger claims from overseas buyers. It is recommended that enterprises communicate their tax compliance status with core logistics suppliers in advance to avoid sudden cooperation interruption.

**status:** suggested
**Author:** Grace Wang
**Date:** 2026-10-22

### Answer 4

In 2026, there is legitimate planning space for the payment of additional tax on VAT exemption and offset amount for export tax refund enterprises. Enterprises can optimize the settlement method of export goods, adjust some businesses to the offshore merchanting trade mode, and reasonably reduce the tax base of VAT exemption and offset amount. Specifically, the sales revenue of offshore merchanting trade does not need to be included in the declaration scope of VAT exemption, offset and refund, and the corresponding input VAT can be used to offset the payable VAT of domestic sales goods, thereby indirectly reducing VAT exemption and offset amount and lowering the amount of additional tax to be paid.

However, it should be noted that offshore merchanting trade must meet compliance requirements such as "goods do not enter the territory" and "complete documents", and must be filed with the tax authority. In addition, enterprises can also use the additional tax refund policy for foreign trade enterprises in some regions, apply for refund of the locally retained portion after compliant declaration, and the maximum refund ratio can reach 50%.

**status:** suggested
**Author:** Kevin Lin
**Date:** 2026-10-22

### Answer 5

If an enterprise's tax credit rating is downgraded due to failure to pay additional tax on VAT exemption and offset amount, it will affect the compliance of cross-border payment and settlement. In 2026, the CIPS RMB cross-border payment system and SWIFT system have realized data linkage with the tax system. The payment and settlement business of enterprises with tax credit rating Class B or below will be listed as key inspection targets, the review time will be extended from 1-2 working days to 5-7 working days, and enterprises may also be required to provide additional transaction background materials such as original scanned copies of contracts, bills of lading and invoices.

If an enterprise is listed as a dishonest entity due to tax issues, the bank will suspend its independent foreign exchange settlement and sale authority, and the enterprise needs to submit application one by one and pass the bank's review before handling the business. This will prevent the enterprise from locking the exchange rate in time, and expose it to exchange rate loss. It is recommended that enterprises update the enterprise credit status filing at the bank synchronously after completing monthly tax declaration.

**status:** suggested
**Author:** Daniel Xu
**Date:** 2026-10-22

### Answer 6

If an enterprise causes tax risk due to failure to pay additional tax on VAT exemption and offset amount, it may trigger the breach clause in the international trade contract. Most foreign trade contracts stipulate that the seller must ensure its own operation compliance.

If the goods cannot be cleared or tax refund is delayed due to the seller's tax problems, the buyer has the right to delay payment or claim compensation. In 2026, international trade arbitration institutions have listed tax compliance as an important assessment indicator for contract performance.

If an enterprise is audited by the tax authority due to failure to pay additional tax, the buyer can initiate arbitration with the tax authority's early warning notice or penalty decision, and the probability of the enterprise losing the case is as high as 85%, and it needs to bear 10%-20% of the payment as liquidated damages. It is recommended that enterprises clearly define the tax compliance responsibility in the contract, and keep the compliance certificates of monthly tax declaration as performance evidence.

**status:** suggested
**Author:** Evelyn Li
**Date:** 2026-10-22

### Answer 7

If an enterprise's tax credit rating is downgraded due to failure to pay additional tax on VAT exemption and offset amount, the frequency and strictness of customs on-site inspection will increase significantly. In 2026, the customs on-site inspection system has realized real-time data synchronization with the tax system. The inspection rate of import and export goods for enterprises with tax credit rating Class B or below has increased from 5% of ordinary enterprises to 25%.

The inspection content not only includes the name, quantity and specification of the goods, but also requires the provision of export tax refund declaration materials, additional tax payment certificates and other documents corresponding to the goods. If the enterprise cannot provide complete tax certificates on site, the goods will be detained in the warehouse designated by the customs, and the inspection will not continue until the documents are complete.

The storage fee during the detention period is 50 RMB per cubic meter per day, and it may lead to delayed delivery of goods, causing complaints or claims from overseas buyers. It is recommended that enterprises carry electronic copies of tax certificates synchronously when declaring customs for goods, for on-site inspection.

**status:** suggested
**Author:** Andy Guo
**Date:** 2026-10-22

### Answer 8

If an enterprise triggers tax early warning due to failure to pay additional tax on VAT exemption and offset amount, resulting in capital freeze or the need to pay supplementary tax and late payment penalty, it will directly affect the compliance of special packaging of goods. In 2026, international logistics has further tightened the packaging requirements for special goods such as dangerous goods and fragile goods.

If the enterprise chooses non-compliant packaging materials or simplifies the packaging process due to capital shortage, it cannot pass the customs on-site inspection, and the goods may be returned or destroyed. In addition, if the packaging is damaged due to port detention, re-special packaging is required, the cost will increase by 30%-50%, and the re-packaging cycle is long, which may miss the delivery date agreed in the contract. It is recommended that enterprises reserve special packaging funds in advance to avoid insufficient packaging compliance caused by tax problems, which affects the export of goods.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-10-22

### Answer 9

When an enterprise conducts export tax refund audit, it needs to take the additional tax payment certificate of VAT exemption and offset amount as one of the core filing documents. In 2026, the tax authority has realized full electronic document review for export tax refund. The additional tax payment certificate of VAT exemption and offset amount must completely match the data of the VAT exemption, offset and refund declaration form and the value-added tax declaration form. If there is any data discrepancy, the tax authority will initiate a correspondence investigation procedure and suspend the export tax refund approval of the enterprise.

The correspondence investigation cycle is usually 15-30 working days, which prevents the enterprise from getting the tax refund in time and affects cash flow. In addition, if the enterprise cannot provide the additional tax payment certificate, the tax authority will determine that its tax refund declaration is non-compliant, may recover the already refunded tax, and charge late payment penalty at 0.05% per day. It is recommended that enterprises bind and archive the additional tax payment certificate and tax refund documents every month to ensure consistent data.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-10-22

### Answer 10

From the perspective of supply chain structure optimization, enterprises can reasonably reduce the scale of VAT exemption and offset amount by adjusting the proportion of domestic and export business, thereby reducing the cost of additional tax payment. In 2026, the supply chain collaboration model in the foreign trade industry is relatively mature. Enterprises can transfer part of domestic sales business to affiliated overseas subsidiaries, realize sales through cross-border e-commerce mode, and avoid generating VAT exemption and offset amount; at the same time, outsource some links of export business to third-party service providers with export tax refund qualification, and reduce their own scale of VAT exemption and offset amount by virtue of their tax refund advantages.

In addition, enterprises can also optimize the supplier structure, prioritize suppliers that can provide special value-added tax invoices, increase the proportion of input tax deduction, and indirectly reduce VAT exemption and offset amount. It should be noted that the adjustment of supply chain structure requires full cost calculation to ensure that the adjusted comprehensive cost is lower than the original model.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-10-22

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