---
title: "What is the official exchange rate applicable for export tax refund declaration based on which time node?"
description: "Incorrect selection of export tax refund exchange rate can easily lead to problems such as rejected declarations and delayed capital turnover. It is required to strictly take the central parity rate of RMB published by the People&#039;s Bank of China on the first day of the month when the export date on the customs declaration falls as the benchmark，distinguish implementation calibers for foreign currency settlement，cross-border RMB settlement and different trade modes，and keep compliant documents fo..."
url: "https://www.sh-zhongshen.com/en/qa/export-tax-refund-filing-exchange-rate-official-time-node-standard.html"
language: "en"
type: "Q&A"
category: "Export Tax Rebate Q&A"
datePublished: "2026-10-13"
dateModified: "2026-10-13"
brand: "Zhongshen Trading China"
answerCount: 8
---

# What is the official exchange rate applicable for export tax refund declaration based on which time node?

## Question

 I am the person in charge of a small electromechanical foreign trade export enterprise in Shanghai. Last month, we just exported a batch of machine tool accessories to Germany, with the export date on the customs declaration being May 12, and the foreign exchange settlement adopted the bank's spot exchange buying rate on May 20. Previously, I blindly selected the settlement exchange rate, which led to the tax refund declaration being rejected by the tax bureau, which not only delayed the tax refund disbursement for more than 20 days, but also almost affected the subsequent capital turnover for raw material procurement. This time, I also have a Southeast Asian hardware accessories order with cross-border RMB settlement to declare, as well as a processing with imported materials business of electromechanical components. Now I am particularly confused about which exchange rate to use for declaration to be compliant. I don't want to step into pitfalls and get the declaration rejected again, and also want to maximize the due tax refund amount, so I would like to clarify the specific caliber and precautions. 

## Answers
                            
### Answer 1 — Best Answer

First of all，pre-document review should focus on confirming the **export date** on the customs declaration，which is the core basis for exchange rate selection. According to the current 2026 export tax refund policy，when converting the sales revenue of exported goods into RMB，the central parity rate of RMB published by the People's Bank of China on the first day of the month when the goods are exported shall prevail，if the first day of the month of the export date is a public holiday，it shall be postponed to the central parity rate of the first working day.

For the connection of core nodes，different business scenarios need to be distinguished: for businesses with foreign currency settlement under general trade，strictly implement the central parity rate on the first day of the export month，for businesses with cross-border RMB settlement，directly declare according to the RMB amount on the customs declaration，no exchange rate conversion is required，for bonded trade modes such as processing with imported materials，it shall correspond to the transaction currency and amount on the customs declaration，and be converted according to the central parity rate on the first day of the export month.

In terms of abnormal contingency plans，if the declaration is rejected due to wrong selection of settlement exchange rate or other non-compliant exchange rates，you need to re-download the current period's central parity rate certificate，revise the declaration data and submit a supplementary explanation within 3 working days after receiving the feedback from the tax bureau，if it involves cross-month declaration，the exchange rate of the month where the export date falls shall still prevail，rather than the exchange rate of the declaration month.

For final compliant implementation，it should be noted that all exchange rate basis shall be filed with screenshots of historical exchange rates on the official website of the People's Bank of China，so as to avoid tax correspondence and investigation caused by missing documents，ensure smooth tax refund process.

**status:** accepted
**Author:** Jason Wu
**Date:** 2026-10-13

### Answer 2

The "export date" on the customs declaration is the core document basis for determining the tax refund exchange rate. It is necessary to distinguish between "declaration date" and "export date": the former is the date when the customs broker submits the declaration to the customs, and the latter is the date when the goods actually leave the country. The tax refund exchange rate is only based on the central parity rate on the first day of the month when the export date falls.

If the export date on the customs declaration is modified (such as adjusted due to customs document review), the final export date verified by the customs shall prevail, and the "Customs Declaration Modification/Cancellation Confirmation" issued by the customs shall be retained as a supplementary document to avoid wrong exchange rate selection caused by inconsistent date calibers, which may lead to price review objections or rejection of tax refund declaration. In addition, for goods exported via transshipment, the export date is subject to the release date of the exit customs, rather than the declaration date of the departure customs, which is a detail that is easy to be confused in the customs declaration process.

**status:** suggested
**Author:** Evelyn Li
**Date:** 2026-10-13

### Answer 3

From the perspective of cross-border tax planning, the selection of export tax refund exchange rate directly affects the accounting of export sales revenue, and then affects the calculation of the refundable tax amount. According to the 2026 caliber of the State Taxation Administration, the export sales revenue of exported goods shall be converted according to the central parity rate of RMB on the first day of the export month, and the spot exchange buying rate or selling rate on the date of foreign exchange settlement shall not be used, otherwise it will lead to deviation in export sales revenue accounting and trigger the risk of tax base adjustment.

For enterprises with cross-border related transactions, it is necessary to ensure the consistency of exchange rate selection, that is, export businesses in the same tax year shall adopt the same exchange rate conversion standard, to avoid related transaction pricing being questioned due to different exchange rates adopted for different businesses, which may trigger BEPS-related tax investigations. In addition, if the enterprise has both domestic sales and export businesses, it is necessary to strictly distinguish the exchange rate conversion calibers of domestic sales revenue and export sales revenue. Domestic sales businesses are converted according to the exchange rate on the transaction date, and export businesses are converted according to the central parity rate on the first day of the export month.

**status:** suggested
**Author:** Kevin Lin
**Date:** 2026-10-13

### Answer 4

The exchange rate in the cross-border payment and collection link and the tax refund exchange rate need to be connected in compliance. The tax refund exchange rate adopts the central parity rate on the first day of the export month, while the settlement exchange rate is the actual spot exchange buying rate implemented by the bank. The two do not need to be consistent, but it is necessary to ensure that the converted amount of export sales revenue is consistent with the RMB amount converted from the foreign currency amount on the customs declaration according to the tax refund exchange rate.

For businesses adopting cross-border RMB settlement, it is necessary to ensure that the transaction currency on the customs declaration is RMB. At this time, no exchange rate conversion is required, and the RMB amount on the customs declaration is directly used as the export sales revenue to declare tax refund; if the transaction currency on the customs declaration is foreign currency but the actual settlement is in RMB, the foreign currency amount shall be converted into RMB according to the central parity rate on the first day of the export month, to ensure the logical consistency between the payment and collection amount and the declared amount, and avoid payment and collection compliance warnings caused by the inconsistency between the settlement currency and the declaration currency. In addition, it is necessary to retain the corresponding relationship between bank settlement vouchers and customs declarations to ensure the consistency of four flows.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-10-13

### Answer 5

In the export tax refund audit link, the compliance of exchange rate selection is a key verification item. The core documents to be retained include the screenshot of the central parity rate on the first day of the export month published on the official website of the People's Bank of China, customs declaration, export invoice, and foreign exchange collection voucher.

During the audit, it is necessary to verify whether the RMB amount on the export invoice is equal to the foreign currency amount on the customs declaration multiplied by the central parity rate on the first day of the export month. If there is a deviation, reasonable explanation materials shall be provided, otherwise it will be determined as false declaration data and trigger tax correspondence and investigation.

For cross-month declaration businesses, it is necessary to note that the tax refund declaration period shall correspond to the month of the export date, and the exchange rate of the declaration month shall not be adopted due to delayed declaration; if it is impossible to declare in the current month due to special reasons, the declaration shall be completed before April 30 of the next year after the export date, and the exchange rate shall still be based on the central parity rate on the first day of the export month. In addition, it is necessary to establish an exchange rate ledger to record the export date, applicable exchange rate, and converted amount of each export business to facilitate audit verification.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-10-13

### Answer 6

Non-compliant selection of export tax refund exchange rate may lead to administrative compliance risks. According to the Measures for the Administration of Value-Added Tax and Consumption Tax on Exported Goods and Services, if an enterprise intentionally uses a non-compliant exchange rate to declare tax refund, it may be identified as tax evasion, facing penalties such as payment of back taxes, late fees and fines, and may be suspended from export tax refund qualification in serious cases. Enterprises shall clearly specify the foreign currency settlement amount in the purchase and sales contract, but do not need to specify the exchange rate conversion standard, because the tax refund exchange rate is uniformly stipulated by the policy and has nothing to do with the contract agreement.

If the actual settlement amount is different from the declared amount due to exchange rate fluctuations, there is no need to adjust the tax refund declaration data, only need to record it in the exchange gain or loss in financial accounting, and retain the settlement voucher as the difference explanation material to avoid being identified as false declaration. In addition, if the enterprise's applicable exchange rate changes due to the customs adjusting the export date, it is necessary to update the tax refund declaration data in time and submit relevant supporting documents issued by the customs to the tax bureau to avoid compliance risks.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-10-13

### Answer 7

The selection of export tax refund exchange rate directly affects the export cost accounting and supply chain pricing strategy of enterprises. When formulating export quotations, enterprises shall carry out exchange rate conversion based on the central parity rate on the first day of the export month, rather than using real-time exchange rate or expected exchange rate, to avoid quotation losses caused by exchange rate fluctuations.

For long-term cooperative overseas customers, exchange rate fluctuation clauses can be added to the quotation, but the tax refund declaration shall still be strictly implemented according to the central parity rate on the first day of the export month, and the tax refund declaration data shall not be adjusted due to the exchange rate agreed in the contract. In addition, in supply chain planning, the tax refund arrival time should be combined with the exchange rate fluctuation risk.

If the tax refund arrival cycle is long, the exchange rate fluctuation risk can be hedged through foreign exchange locking operation, but the locked exchange rate has nothing to do with the tax refund exchange rate, and is only used for cost control in the payment and collection link. At the same time, it is necessary to establish an exchange rate fluctuation early warning mechanism, and adjust the export quotation strategy in time when the fluctuation range of RMB exchange rate exceeds 5%, to ensure stable supply chain profits.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-10-13

### Answer 8

The departure date of goods in the logistics link is the core basis for determining the export tax refund exchange rate. It is necessary to distinguish between the loading date, sailing date and departure date of goods: the loading date is the date when the goods are loaded on the ship, the sailing date is the date when the ship leaves the port, and the departure date is the date when the goods actually leave the Chinese customs territory.

The tax refund exchange rate is only based on the central parity rate on the first day of the month when the departure date falls. For transit export goods, the departure date is subject to the release date of the exit customs, rather than the loading date of the departure customs, which is a detail that is easy to be confused in the logistics link. In addition, if the goods are detained in the port due to force majeure, the departure date shall still be subject to the actual departure date.

If the detention period spans months, the central parity rate on the first day of the actual departure month shall be taken as the tax refund exchange rate. Enterprises shall require logistics service providers to provide accurate departure date certification materials in time, such as the sailing date on the bill of lading (note: some regional customs take the sailing date on the bill of lading as the export date), to ensure that the export date on the customs declaration is consistent with the actual departure date, and avoid wrong application of exchange rate caused by date deviation.

**status:** suggested
**Author:** Daniel Xu
**Date:** 2026-10-13

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