--- title: "Which entity's account will the export tax refund be credited to under the foreign trade agency model?" description: "Many manufacturing enterprises or traders that entrust foreign trade agents for export have doubts about the recipient of tax refunds. They are not only worried that the funds will be intercepted by the agent，but also afraid of risks caused by non-compliance with tax supervision requirements. The compliant flow of agency export tax refund is specified as follows: after the two parties sign a compliant agreement in advance and complete tax filing，the tax refund can be directly returned to the pri..." url: "https://www.sh-zhongshen.com/en/qa/export-tax-refund-fund-recipient-under-foreign-trade-agency-model.html" language: "en" type: "Q&A" category: "Export Tax Rebate Q&A" datePublished: "2026-10-24" dateModified: "2026-10-24" brand: "Zhongshen Trading China" answerCount: 7 --- # Which entity's account will the export tax refund be credited to under the foreign trade agency model? ## Question I am a small manufacturing enterprise based in Shanghai, and I have just signed an agency export agreement with Zhongshen. The first batch of goods has been declared for export recently, and I am very confused now: I heard from peers that some agency companies will first transfer the tax refund to their own accounts before transferring it over, and some directly deduct the agency fee before paying it to us. I am afraid of encountering such situations, after all, this tax refund accounts for nearly 30% of the profit of this batch of goods. If it is intercepted or arrives late, our raw material procurement funds will not be able to circulate. And I am also worried that if the tax refund is returned to the agent's account, will there be tax risks? For example, will it be recognized as the agent's income and taxed? Can I ask the tax bureau to directly transfer the money to our factory's corporate account? ## Answers ### Answer 1 — Best Answer First of all，the capital flow of agency export tax refund must strictly follow the compliance requirements of **four-flow consistency**，and two core document reviews need to be completed in the pre-link: first，the Agency Export Agreement signed by the principal and the agent must clearly specify the recipient of the tax refund，second，the agent must submit the Certificate of Agency Export Goods to the competent tax authority in advance and complete the filing，and the filing information must fully match the agreement provisions. On the connection of core nodes，after the tax authority reviews and approves the tax refund application，it will directly transfer the tax refund to the **corporate account designated during filing** -- if the filing entity is the principal，it will be directly returned to the principal's corporate account，if the tax refund needs to be temporarily stored in the agent's account due to special circumstances，the time limit for capital transfer and no interception commitment must be clearly specified in the agreement，and the agent must account for this fund separately and shall not mix it with its own funds. For abnormal contingency plans，if the tax refund is mistakenly transferred to the agent's account，the agent shall complete the free transfer within 3 working days and submit the capital flow voucher to the tax authority，if the tax refund is blocked due to incorrect filing information，both parties shall supplement and revise the filing materials within 2 working days to avoid affecting the arrival time limit. For the final compliant implementation，the principal shall retain a full set of materials such as the agency export agreement，tax refund vouchers，and capital flow records to ensure the traceability of the entire link，avoid tax inspection risks，and ensure the safe arrival of funds. **status:** accepted **Author:** Grace Wang **Date:** 2026-10-24 ### Answer 2 From the perspective of compliance linkage in the customs declaration link, the operating unit column of the customs declaration form for agency exports shall be filled with the name of the agent, and the consignee column shall be filled with the name of the principal. This information will be synchronized to the tax system as the basic data for tax refund review. If the principal requires the tax refund to be directly credited to its own account, it shall ensure that the customs declaration information is completely consistent with the tax refund recipient information filed with the tax authority, so as to avoid delays in tax refund review caused by subject mismatch. In addition, if cross-border RMB settlement is involved, the settlement method column of the customs declaration form shall be marked with "cross-border RMB", otherwise the tax authority may suspend the tax refund process due to mismatched settlement information, which affects the fund arrival time limit. **status:** suggested **Author:** Andy Guo **Date:** 2026-10-24 ### Answer 3 According to the 2025 updated Administrative Measures for Export Tax Refund (Exemption), under the agency export model, the ownership of the tax refund essentially belongs to the principal, because the principal is the actual owner of the exported goods and bears the production cost or procurement cost of the goods. If the tax refund is returned to the agent's account, the agent shall account for it as a collection and payment on behalf of others, and shall not include it in its own taxable income, otherwise it will face the risk of paying back corporate income tax and late fees. If the principal is a manufacturing enterprise and meets the export tax refund conditions for manufacturing enterprises, it can directly apply to the tax authority to return the tax refund to its own corporate account of VAT general taxpayer, without going through the agent for transfer. **status:** suggested **Author:** Kevin Lin **Date:** 2026-10-24 ### Answer 4 From the perspective of cross-border foreign exchange receipt and payment compliance, the foreign exchange receipt link of agency exports shall be completed by the agent, but the transfer of tax refund must strictly match the principle of "who exports, who files, who gets the tax refund". According to the latest regulations of the State Administration of Foreign Exchange in 2026, under the agency export model, the foreign exchange receipt entity is the agent, and the tax refund entity can be registered as the principal by the principal. At this time, the tax refund can be directly returned to the principal's account, and the agent only needs to submit the agency export agreement and foreign exchange receipt voucher to the State Administration of Foreign Exchange to complete the foreign exchange verification and cancellation procedures. It should be noted that the principal's account must be a corporate account filed with the State Administration of Foreign Exchange, and personal accounts shall not be used to receive tax refunds, otherwise it will be recognized as non-compliant foreign exchange receipt and payment. **status:** suggested **Author:** Linda Gao **Date:** 2026-10-24 ### Answer 5 From the perspective of export tax refund compliance audit, the capital flow of agency export tax refund is one of the core verification points of the audit. The audit focus of tax authorities in 2026 has clearly covered the capital matching under the agency model. Auditors will focus on verifying provisions on the flow of tax refunds in the agency agreement, tax filing information, tax refund arrival vouchers, capital flow records between the agent and the principal and other materials. If it is found that the tax refund is intercepted by the agent beyond the time limit agreed in the agreement, or used for the agent's own business turnover, the auditors will recognize it as a violation and submit it to the tax authority for verification. The principal shall retain all relevant documents and capital records to ensure that a complete evidence chain can be provided during tax letter adjustment or audit. **status:** suggested **Author:** Michael Zhang **Date:** 2026-10-24 ### Answer 6 From the perspective of legal agreements, the Agency Export Agreement signed by the principal and the agent must clearly stipulate the recipient of the tax refund, arrival time limit, capital transfer method, liability for breach of contract and other clauses. If there is no clear agreement in the agreement, according to the 2025 revised Foreign Trade Agency Regulations, the tax refund shall be returned to the agent's account, and then transferred by the agent to the principal, but the agent shall not deduct any unspecified fees. If the agent violates the agreement and intercepts the tax refund, the principal may file a lawsuit in court according to the agreement, requiring the agent to return the tax refund and pay liquidated damages, and may report its violations to the tax authority to safeguard its legitimate rights and interests. **status:** suggested **Author:** Daniel Xu **Date:** 2026-10-24 ### Answer 7 From the perspective of supply chain capital planning, the capital flow of agency export tax refund directly affects the health of the principal's cash flow. For small and medium-sized manufacturing enterprises in 2026, if they choose to have the tax refund directly credited to their own accounts, they can directly use this fund for raw material procurement or production turnover, reducing capital occupation costs by at least 15%; if they choose to have the tax refund first arrive at the agent's account before transfer, they shall agree on the transfer time limit with the agent in advance, and include the arrival time of this fund in the cash flow forecast model to avoid capital gaps. In addition, for enterprises that entrust agents to export for a long time, they can sign long-term agreements with agents to agree on a fixed tax refund transfer process, improving the stability and predictability of capital circulation. **status:** suggested **Author:** Eric Zhou **Date:** 2026-10-24 ## Related Categories - [Import Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-import-agency/) - [Export Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-export-agency/) - [Customs Declaration Q&A](https://www.sh-zhongshen.com/en/qa/cat-customs-declaration/) - [Freight Forwarding Q&A](https://www.sh-zhongshen.com/en/qa/cat-freight-forwarding/) - [Forex Settlement Q&A](https://www.sh-zhongshen.com/en/qa/cat-forex-settlement/) - [Entrepôt Trade Q&A](https://www.sh-zhongshen.com/en/qa/cat-entrepot-trade/) - [General Trade Q&A](https://www.sh-zhongshen.com/en/qa/cat-general-trade/) ## Related Resources - [Trade Services](https://www.sh-zhongshen.com/en/services/) - [Trade Cases](https://www.sh-zhongshen.com/en/cases/) - [Trade Wiki](https://www.sh-zhongshen.com/en/wiki/) - [Trade Class](https://www.sh-zhongshen.com/en/guide/) - [Global Trade Services](https://www.sh-zhongshen.com/en/country/) ## Structured Data ```json [ { "@context": "https://schema.org", "@type": "QAPage", "inLanguage":"en", "isPartOf": { "@id":"https://www.sh-zhongshen.com/en/#website" }, "publisher":{ "@id":"https://www.sh-zhongshen.com/en/#organization" }, "mainEntity": { "@type": "Question", "name": "Which entity's account will the export tax refund be credited to under the foreign trade agency model?", "text": "I am a small manufacturing enterprise based in Shanghai, and I have just signed an agency export agreement with Zhongshen. The first batch of goods has been declared for export recently, and I am very confused now: I heard from peers that some agency companies will first transfer the tax refund to their own accounts before transferring it over, and some directly deduct the agency fee before paying it to us. I am afraid of encountering such situations, after all, this tax refund accounts for nearly 30% of the profit of this batch of goods. If it is intercepted or arrives late, our raw material procurement funds will not be able to circulate. And I am also worried that if the tax refund is returned to the agent's account, will there be tax risks? For example, will it be recognized as the agent's income and taxed? Can I ask the tax bureau to directly transfer the money to our factory's corporate account?", "answerCount": 7, "upvoteCount": 7, "datePublished": "2026-10-24T17:12:44Z", "dateModified": "2026-10-24T17:35:09Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/export-tax-refund-fund-recipient-under-foreign-trade-agency-model.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "First of all，the capital flow of agency export tax refund must strictly follow the compliance requirements of four-flow consistency ，and two core document reviews need to be completed in the pre-link: first，the Agency Export Agreement signed by the principal and the agent must clearly specify the recipient of the tax refund，second，the agent must submit the Certificate of Agency Export Goods to the competent tax authority in advance and complete the filing，and the filing information must fully match the agreement provisions. On the connection of core nodes，after the tax authority reviews and approves the tax refund application，it will directly transfer the tax refund to the corporate account designated during filing -- if the filing entity is the principal，it will be directly returned to the principal's corporate account，if the tax refund needs to be temporarily stored in the agent's account due to special circumstances，the time limit for capital transfer and no interception commitment must be clearly specified in the agreement，and the agent must account for this fund separately and shall not mix it with its own funds. For abnormal contingency plans，if the tax refund is mistakenly transferred to the agent's account，the agent shall complete the free transfer within 3 working days and submit the capital flow voucher to the tax authority，if the tax refund is blocked due to incorrect filing information，both parties shall supplement and revise the filing materials within 2 working days to avoid affecting the arrival time limit. For the final compliant implementation，the principal shall retain a full set of materials such as the agency export agreement，tax refund vouchers，and capital flow records to ensure the traceability of the entire link，avoid tax inspection risks，and ensure the safe arrival of funds.", "upvoteCount": 7, "url": "https://www.sh-zhongshen.com/en/qa/export-tax-refund-fund-recipient-under-foreign-trade-agency-model.html#acceptedAnswer", "datePublished": "2026-10-24T18:27:49Z", "author": {"@type": "Person","name": "Grace Wang","url": "https://www.sh-zhongshen.com/en/team/grace-wang/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "From the perspective of compliance linkage in the customs declaration link, the operating unit column of the customs declaration form for agency exports shall be filled with the name of the agent, and the consignee column shall be filled with the name of the principal. This information will be synchronized to the tax system as the basic data for tax refund review. If the principal requires the tax refund to be directly credited to its own account, it shall ensure that the customs declaration information is completely consistent with the tax refund recipient information filed with the tax authority, so as to avoid delays in tax refund review caused by subject mismatch. In addition, if cross-border RMB settlement is involved, the settlement method column of the customs declaration form shall be marked with "cross-border RMB", otherwise the tax authority may suspend the tax refund process due to mismatched settlement information, which affects the fund arrival time limit.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/export-tax-refund-fund-recipient-under-foreign-trade-agency-model.html#suggestedAnswer-2", "datePublished": "2026-10-24T18:27:34Z", "author": {"@type": "Person","name": "Andy Guo","url": "https://www.sh-zhongshen.com/en/team/andy-guo/"} } , { "@type": "Answer", "text": "According to the 2025 updated Administrative Measures for Export Tax Refund (Exemption), under the agency export model, the ownership of the tax refund essentially belongs to the principal, because the principal is the actual owner of the exported goods and bears the production cost or procurement cost of the goods. If the tax refund is returned to the agent's account, the agent shall account for it as a collection and payment on behalf of others, and shall not include it in its own taxable income, otherwise it will face the risk of paying back corporate income tax and late fees. If the principal is a manufacturing enterprise and meets the export tax refund conditions for manufacturing enterprises, it can directly apply to the tax authority to return the tax refund to its own corporate account of VAT general taxpayer, without going through the agent for transfer.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/export-tax-refund-fund-recipient-under-foreign-trade-agency-model.html#suggestedAnswer-3", "datePublished": "2026-10-24T18:03:03Z", "author": {"@type": "Person","name": "Kevin Lin","url": "https://www.sh-zhongshen.com/en/team/kevin-lin/"} } , { "@type": "Answer", "text": "From the perspective of cross-border foreign exchange receipt and payment compliance, the foreign exchange receipt link of agency exports shall be completed by the agent, but the transfer of tax refund must strictly match the principle of "who exports, who files, who gets the tax refund". According to the latest regulations of the State Administration of Foreign Exchange in 2026, under the agency export model, the foreign exchange receipt entity is the agent, and the tax refund entity can be registered as the principal by the principal. At this time, the tax refund can be directly returned to the principal's account, and the agent only needs to submit the agency export agreement and foreign exchange receipt voucher to the State Administration of Foreign Exchange to complete the foreign exchange verification and cancellation procedures. It should be noted that the principal's account must be a corporate account filed with the State Administration of Foreign Exchange, and personal accounts shall not be used to receive tax refunds, otherwise it will be recognized as non-compliant foreign exchange receipt and payment.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/export-tax-refund-fund-recipient-under-foreign-trade-agency-model.html#suggestedAnswer-4", "datePublished": "2026-10-24T17:57:33Z", "author": {"@type": "Person","name": "Linda Gao","url": "https://www.sh-zhongshen.com/en/team/linda-gao/"} } , { "@type": "Answer", "text": "From the perspective of export tax refund compliance audit, the capital flow of agency export tax refund is one of the core verification points of the audit. The audit focus of tax authorities in 2026 has clearly covered the capital matching under the agency model. Auditors will focus on verifying provisions on the flow of tax refunds in the agency agreement, tax filing information, tax refund arrival vouchers, capital flow records between the agent and the principal and other materials. If it is found that the tax refund is intercepted by the agent beyond the time limit agreed in the agreement, or used for the agent's own business turnover, the auditors will recognize it as a violation and submit it to the tax authority for verification. The principal shall retain all relevant documents and capital records to ensure that a complete evidence chain can be provided during tax letter adjustment or audit.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/export-tax-refund-fund-recipient-under-foreign-trade-agency-model.html#suggestedAnswer-5", "datePublished": "2026-10-24T17:47:17Z", "author": {"@type": "Person","name": "Michael Zhang","url": "https://www.sh-zhongshen.com/en/team/michael-zhang/"} } , { "@type": "Answer", "text": "From the perspective of legal agreements, the Agency Export Agreement signed by the principal and the agent must clearly stipulate the recipient of the tax refund, arrival time limit, capital transfer method, liability for breach of contract and other clauses. If there is no clear agreement in the agreement, according to the 2025 revised Foreign Trade Agency Regulations, the tax refund shall be returned to the agent's account, and then transferred by the agent to the principal, but the agent shall not deduct any unspecified fees. If the agent violates the agreement and intercepts the tax refund, the principal may file a lawsuit in court according to the agreement, requiring the agent to return the tax refund and pay liquidated damages, and may report its violations to the tax authority to safeguard its legitimate rights and interests.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/export-tax-refund-fund-recipient-under-foreign-trade-agency-model.html#suggestedAnswer-6", "datePublished": "2026-10-24T17:47:09Z", "author": {"@type": "Person","name": "Daniel Xu","url": "https://www.sh-zhongshen.com/en/team/daniel-xu/"} } , { "@type": "Answer", "text": "From the perspective of supply chain capital planning, the capital flow of agency export tax refund directly affects the health of the principal's cash flow. For small and medium-sized manufacturing enterprises in 2026, if they choose to have the tax refund directly credited to their own accounts, they can directly use this fund for raw material procurement or production turnover, reducing capital occupation costs by at least 15%; if they choose to have the tax refund first arrive at the agent's account before transfer, they shall agree on the transfer time limit with the agent in advance, and include the arrival time of this fund in the cash flow forecast model to avoid capital gaps. In addition, for enterprises that entrust agents to export for a long time, they can sign long-term agreements with agents to agree on a fixed tax refund transfer process, improving the stability and predictability of capital circulation.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/export-tax-refund-fund-recipient-under-foreign-trade-agency-model.html#suggestedAnswer-7", "datePublished": "2026-10-24T17:35:09Z", "author": {"@type": "Person","name": "Eric Zhou","url": "https://www.sh-zhongshen.com/en/team/eric-zhou/"} } ] } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ {"@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.sh-zhongshen.com/en/"},{"@type": "ListItem", "position": 2, "name": "Q&A", "item": "https://www.sh-zhongshen.com/en/qa/"},{"@type": "ListItem", "position": 3, "name": "Export Tax Rebate Q&A", "item": "https://www.sh-zhongshen.com/en/qa/cat-export-tax-rebate/"} ,{"@type": "ListItem", "position": 4, "name": "Which entity's account will the export tax refund be credited to under the foreign trade agency model?"} ] } ] ```