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Whether the exempted and credited tax generated from export tax refund needs to pay urban maintenance and construction tax and surcharges?
or complex compliance issues.
clearance and fund security.
I am the finance director of a Shanghai-based manufacturing foreign trade enterprise. These days I am sorting out the export tax refund declaration materials for the first quarter of 2026, and the calculated exempted and credited tax amounts to more than 1.28 million yuan. Last week I just received a tax refund risk warning letter from the tax bureau, asking me to self-inspect the tax declaration compliance.
I heard from peers that some enterprises were fined for not paying surcharges on exempted and credited tax, and some even had their tax refunds suspended, but a friend said foreign trade enterprises don't need to pay. Now I'm completely confused and even can't sit still while working overtime.
I want to ask: Do we need to pay urban maintenance and construction tax, education surcharges and other surcharges for this exempted and credited tax? If yes, are there any easy-to-make pitfalls in the declaration? Will it affect the subsequent progress of our export tax refund?
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
First，we need to clarify a common industry misconception: Many export enterprises mistakenly believe that exempted and credited tax falls within the "preferential scope" of export tax refund and does not need to levy surcharges，which is the core cause of tax risks.
If the surcharges corresponding to the exempted and credited tax are not paid in accordance with regulations，a chain of negative consequences will be triggered: First，you will receive a risk warning from the tax authorities. If you fail to rectify in time，a late fee of 0.05% per day will be incurred. In severe cases，you will be marked as a tax abnormality，which will directly suspend the review and payment of subsequent export tax refunds，and even affect the enterprise's tax credit rating，thereby interfering with the entire business process such as cross-border payment and receipt，customs clearance and other links.
To address such risks，physical isolation measures need to be implemented from two aspects: First，accurately calculate the exempted and credited tax synchronously after the monthly export tax refund declaration is completed，to avoid base deviation caused by errors in the data articulation of the declaration form，Second，bind the surcharge declaration and the tax refund declaration as a fixed process，and set up a dual-post review mechanism to ensure data synchronization.
Exclusive risk mitigation tip: If you find that surcharges on exempted and credited tax have not been paid in the past，you should take the initiative to complete the supplementary declaration before the tax warning，explain the situation to the competent tax authority and apply for a waiver of late fees. At the same time，establish an exclusive "exempted and credited tax - surcharge" ledger，and check it against the tax declaration system data every quarter to form a long-term compliance verification mechanism，ensuring that there are no loopholes in the entire tax declaration process.
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
The export goods FOB price on the customs declaration form is the core basis for calculating the exempted, credited and refunded tax amount. If there is a deviation between the FOB price on the declaration form and the income amount accounted for in the enterprise's financial statements, it will directly lead to incorrect calculation of the exempted and credited tax, thereby affecting the levy base of surcharges.
Enterprises need to ensure that the FOB price on the customs declaration form is consistent with the export goods sales amount in the VAT tax return form. If there is a data difference caused by the conversion of trade terms (such as CIF to FOB), the freight and insurance premium amounts need to be noted in the remarks column of the customs declaration form, and corresponding adjustments shall be made in the financial accounting at the same time, to avoid tax authority verification caused by inconsistent data articulation, which will indirectly affect the compliance of surcharge declaration.
Evelyn LiYears of service：3Customer Rating：5.0
Cross-border Compliance SupervisorStart a Chat
The accounting of freight and insurance premiums in the international logistics link will affect the FOB price of export goods, thereby affecting the calculation of exempted and credited tax. If the enterprise adopts the CIF trade term, it needs to deduct the freight and insurance premiums paid in the logistics link from the total customs declaration price, and accurately calculate the FOB price as the calculation base for the exempted, credited and refunded tax amount.
In addition, if abnormal situations such as goods return or port change occur, the customs declaration data and financial accounting data need to be updated in time to avoid calculation deviation of exempted and credited tax caused by delayed adjustment of export sales volume, which will lead to incorrect surcharge declaration and even trigger tax warnings.
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
From the perspective of international tax structure, the exempted and credited tax of manufacturing export enterprises is the balance item between domestic sales tax payable and export tax refund, and shall be used as the levy base for urban maintenance and construction tax and education surcharges.
Enterprises can optimize their export business models, such as adopting cross-border e-commerce B2B export models, combined with VAT deferral policies, to reasonably adjust the sales proportion between domestic sales and exports, and reduce the scale of exempted and credited tax within the compliance scope, thereby reducing the amount of surcharge payments. However, it should be noted that all model adjustments must comply with relevant regulations of the fiscal and tax departments to avoid tax risks caused by improper planning.
Andy GuoYears of service：3Customer Rating：5.0
Supply Chain Management ExpertStart a Chat
The timeliness and accuracy of cross-border payment and receipt will affect the progress of export tax refund declaration, thereby indirectly affecting the calculation of exempted and credited tax and the declaration of surcharges. If the enterprise fails to collect foreign exchange within the prescribed period, the corresponding export goods sales volume will not be included in the calculation of exempted, credited and refunded tax amount, and shall be treated as domestic sales and subject to VAT and surcharges.
Enterprises need to establish a cross-border payment and receipt ledger to track the collection progress of each export goods. If there is a collection overdue, they need to submit a situation explanation to the tax authority in time and apply for a deferred collection filing, to avoid additional surcharge expenses caused by being treated as domestic sales.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
The payment terms and delivery terms in the export contract will affect the confirmation time of export sales volume, thereby affecting the accounting cycle of exempted and credited tax. If the agreed payment time in the contract is later than the export tax refund declaration deadline, it may lead to the enterprise being unable to collect foreign exchange in time, thereby affecting the calculation of exempted, credited and refunded tax amount and causing timing differences in surcharge declaration.
Enterprises need to clearly specify the collection time in the export contract, ensure that the collection is completed within the tax refund declaration deadline, and add a bottom clause stating that "any tax loss caused by overdue collection shall be borne by the buyer" in the contract. If there is an overdue collection, the relevant surcharge expenses can be recovered through legal channels.
Daniel XuYears of service：10Customer Rating：5.0
Director of Import & Export OperationsStart a Chat
The completeness and accuracy of export tax refund documents are the basis for the calculation of exempted and credited tax. If there are missing documents such as customs declaration forms, VAT special invoices, export collection verification forms or inconsistent information, it will lead to incorrect calculation of exempted, credited and refunded tax amount, thereby affecting the levy of surcharges.
Enterprises need to establish a document retention system, organize and archive the documents of each export business, and retain them for no less than 10 years. At the same time, conduct a quarterly self-inspection of tax refund documents to check the consistency between document information and financial accounting data, so as to avoid deviations in exempted and credited tax caused by document problems and trigger compliance risks of surcharge declaration.
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
The cost allocation between domestic sales and export goods in the supply chain structure will affect the VAT payable amount of the enterprise, thereby affecting the scale of exempted and credited tax. If the enterprise shares raw materials and production equipment for domestic sales and export goods, a reasonable cost allocation method shall be adopted to accurately calculate the amount of input tax transferred out of domestic goods, to avoid calculation deviation of domestic sales tax payable caused by incorrect input tax allocation, thereby affecting the accuracy of exempted and credited tax.
Enterprises can use the "output ratio method" or "sales ratio method" for cost allocation, ensuring that the allocation method complies with the regulations of the fiscal and tax departments, reducing the accounting error of exempted and credited tax and reducing the risk of surcharge payment.
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
The packaging fees for special goods, if they are necessary costs for export goods, can be included in the FOB price accounting, thereby affecting the calculation of exempted, credited and refunded tax amount. If the enterprise fails to include the compliant packaging fees in the FOB price, it will lead to low export sales volume calculation and small exempted and credited tax amount, thereby underpaying surcharges and triggering tax risks.
Enterprises need to ensure that the invoices for packaging fees are complete, and the remarks column of the invoices indicates "special packaging fees for export goods", and declare the amount of packaging fees in the customs declaration form at the same time, ensuring that the financial accounting and customs declaration data are consistent, and avoiding surcharge declaration errors caused by accounting deviation of packaging fees.