Does Export Tax Refund Cover Taxes and Duties Related to Freight? What Are the Core Judgment Criteria in Practice?

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I am the head of a foreign trade enterprise in Shanghai focusing on mechanical and electrical product export. Last week, we shipped a European order under CIF terms, and we included both ocean freight and insurance premium in the total declared value during customs declaration. Now the finance team is preparing for tax refund declaration, but is stuck on the issue of whether taxes related to freight are refundable. I heard from peers that it is refundable in some cases but not in others, and I did not fully understand the details after going through policy documents.

The freight of this shipment accounts for 12% of the total cargo value, and if refundable, it can save nearly 20,000 yuan in costs. But I am also afraid that filling in the declaration items incorrectly will lead to tax inspection and delay the tax refund progress of subsequent orders. I am very anxious now and want to ask for clarification: Does export tax refund cover taxes on freight? Are there differences in processing rules under different trade terms, and what details should be paid attention to during declaration?

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Expert Q&A

Eric Zhou
Eric ZhouYears of service:6Customer Rating:5.0

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

There are two core bases for judging whether export tax refund covers taxes related to freight: first,whether the freight is included in the total declared value of export goods,and second,whether compliant freight deduction vouchers are obtained. For freight under CIF terms that has been included in the total declared value,it needs to be separately stated on the customs declaration form,and special VAT invoices or international freight forwarding service invoices must be obtained before it can be included in the tax refund scope,freight not separately stated or with non-compliant vouchers cannot enjoy tax refund.

For pre-document review,key attention should be paid to: whether the amount in the freight column on the customs declaration form is truthfully filled in,whether the title and amount of the freight invoice fully match the customs declaration form,to ensure consistency of goods flow,fund flow,invoice flow and customs declaration flow. In terms of core node connection,the freight amount should be filled in the corresponding tax calculation column separately during tax refund declaration,and accounted for separately from the cargo value,to avoid declaration system errors caused by mixed filling.

Abnormal response plan: If the amount on the freight invoice does not match the amount on the customs declaration form,immediately contact the freight forwarder to adjust the invoice or apply to the customs for modifying the customs declaration form,if the tax authority initiates letter verification,provide supporting materials such as transportation contracts and freight forwarding agreements in time. Final compliance implementation: After completing pre-declaration verification and confirming no abnormalities,submit the formal declaration to ensure that taxes related to freight are smoothly included in the tax refund scope.

Reference: Comprehensive Analysis of Tax Treatment for Agented Export Receipts, In-depth Interpretation of 2026 Latest Policies
Cindy Chen
Cindy ChenYears of service:3Customer Rating:5.0

Key Account ManagerStart a Chat

From the perspective of customs valuation, the dutiable value of export goods is based on FOB, and freight under CIF terms needs to be deducted from the total declared value to calculate the dutiable value, but the processing is different for tax refund calculation. If the freight has been truthfully filled in the "freight" column of the customs declaration form separately, and the corresponding transportation service directly corresponds to this batch of export goods, then this part of freight can be included in the tax refund scope as additional charges outside the commodity price of export goods.

Note: Freight not separately stated will be regarded by the customs as part of the total cargo value, but if corresponding vouchers cannot be provided, it still cannot be recognized during tax refund. During customs declaration, ensure that the amount in the freight column is consistent with the actual payment voucher, to avoid blocked tax refund declaration caused by valuation disputes.

Linda Gao
Linda GaoYears of service:7Customer Rating:5.0

Documentation SupervisorStart a Chat

The party responsible for freight varies under different trade terms, which directly affects tax refund recognition. Under FOB terms, the freight is borne by the buyer, and the exporter does not need to include the freight in the total declared value, so there is naturally no tax refund issue; under CIF/CFR terms, the freight is borne by the exporter and needs to be included in the total declared value, but two conditions must be met for tax refund: first, the transportation route is the full journey from within China to the overseas destination, second, the obtained freight forwarder invoice or ocean bill of lading clearly indicates the transportation information of the corresponding batch of goods.

If there is transshipment freight, separately split the domestic segment and overseas segment freight, only the domestic segment freight can be included in the tax refund scope, and the overseas segment freight cannot enjoy tax refund.

Grace Wang
Grace WangYears of service:10Customer Rating:5.0

Senior Foreign Trade ConsultantStart a Chat

From the perspective of cross-border tax planning, the tax refund recognition of freight can be optimized by reasonable selection of trade terms. For freight under CIF terms, ensure that it is included in the sales revenue of export goods and compliant VAT deduction vouchers are obtained, so that it can be applied for tax refund as part of the input tax amount.

If a separate contract is signed for freight and invoices are issued separately, it should be accounted for together with the cargo value during tax refund declaration, to avoid vague recognition of tax calculation scope caused by splitting. In addition, if enterprises use VAT deferral to pay import-related taxes and duties, note that taxes on export freight cannot be confused with import deferred taxes, and should be declared for tax refund separately.

Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

From the perspective of foreign exchange receipt and payment compliance, the payment of export freight must be consistent with the amount on the customs declaration form, and the fund flow must directly go to the entity providing transportation services, and cannot be transferred through a third party, otherwise it cannot be recognized during tax refund due to inconsistency between fund flow and invoice flow.

If CIPS is used for payment, ensure that the remark in the payment message clearly indicates "export cargo transportation fee" and the corresponding customs declaration number, to facilitate verification by the tax authority. In addition, when paying freight through an offshore account, keep payment vouchers, transportation contracts and other materials as supporting documents for tax refund declaration, to avoid tax refund application rejection due to non-compliant foreign exchange receipt and payment.

Victor Sun
Victor SunYears of service:5Customer Rating:5.0

Trade Risk Control ManagerStart a Chat

From the perspective of international trade contracts, trade terms should clearly specify the party responsible for freight, amount and invoice issuance requirements, to avoid tax refund disputes caused by vague contract agreements. For example, under CIF terms, it should be stated in the contract that "freight includes corresponding taxes, borne by the seller and the seller will obtain compliant invoices", to ensure that there is a contract basis for subsequent tax refund.

If the freight forwarder's breach of contract leads to failure to provide compliant freight invoices, the freight forwarder can be required to bear liability for breach of contract according to the contract agreement, including compensation for losses caused by failure to obtain tax refund. In addition, note that the signing entity of the transportation contract must be consistent with the invoice issuing entity, to avoid invalidation of vouchers due to inconsistent entities.

Michael Zhang
Michael ZhangYears of service:6Customer Rating:5.0

Customs Declaration & Compliance ExpertStart a Chat

During the on-site inspection process, if the customs finds that the freight amount on the customs declaration form is inconsistent with the actual transportation voucher, it will launch the valuation review procedure, leading to port detention of goods, which will further affect the time node of tax refund declaration. At this time, immediately provide supporting materials such as transportation contracts, freight forwarder invoices and bills of lading to prove the authenticity of the freight amount.

If the port detention time is long, apply to the customs for inspection and release priority in time to avoid detention fees. In addition, if inspection abnormality occurs due to unclear freight labeling, update the document information of tax refund declaration in time after the customs declaration form is modified, to ensure consistency with customs data.

Kevin Lin
Kevin LinYears of service:4Customer Rating:5.0

Trade Solutions ManagerStart a Chat

From the perspective of tax refund audit, the tax refund recognition of freight must meet the core requirement of "consistency of four streams": goods flow corresponds to transportation services, fund flow is consistent with the freight payment amount, invoice flow is consistent with the transportation entity, and customs declaration flow is consistent with the label of the freight column. Common tax refund audit doubts include: abnormal ratio of freight amount to cargo value, too long interval between invoice issuance time and customs declaration time, failure to keep supporting materials such as transportation contracts.

If selected for audit spot check, submit the full set of documents within the specified time, otherwise the tax refund qualification will be suspended. In addition, cross-month declared freight must be submitted together in the tax refund declaration of the next month, and cannot be declared delayed.

Andy Guo
Andy GuoYears of service:3Customer Rating:5.0

Supply Chain Management ExpertStart a Chat

From the perspective of supply chain planning, reasonable selection of transportation schemes can optimize the tax refund income of freight. For example, selecting freight forwarders that sign long-term transportation agreements with export enterprises can ensure the timeliness and compliance of freight invoices, facilitating inclusion in the tax refund scope.

In terms of trade term conversion, if an enterprise originally adopts FOB terms, it can convert to CIF terms and bear the freight by itself, reducing the overall cost by including the freight in the tax refund scope. Note: The tax refund rules for freight of different transportation modes (ocean freight, air freight, land freight) are the same, all requiring compliant vouchers and statement on the customs declaration form as prerequisites, and there is no need to adjust the declaration strategy according to transportation modes.

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