---
title: "What is the complete compliance process for export tax refund declaration under EXW trade terms?"
description: "When foreign trade enterprises carry out business under EXW terms，they often get stuck in tax refund declaration due to problems such as title transfer and poor document coordination，and even trigger compliance risks such as tax correspondence verification and tax refund delay. Through pre-audit of core documents such as customs declaration forms and input invoices，precise connection of logistics and fiscal and taxation nodes，and formulation of contingency plans for abnormal supplementary declar..."
url: "https://www.sh-zhongshen.com/en/qa/exw-term-export-tax-refund-declaration-compliance-process.html"
language: "en"
type: "Q&A"
category: "Export Tax Rebate Q&A"
datePublished: "2026-05-11"
dateModified: "2026-05-11"
brand: "Zhongshen Trading China"
answerCount: 10
---

# What is the complete compliance process for export tax refund declaration under EXW trade terms?

## Question

 I am the person in charge of a foreign trade enterprise in Shanghai specializing in the export of electromechanical parts. Last month, we shipped two batches of goods to Germany under EXW terms, and this is our first time handling tax refund declaration under the EXW model. We have been operating under FOB terms before, and we managed the customs declaration process ourselves. This time, the freight forwarder is responsible for customs declaration and logistics. I only have the special input VAT invoice issued by the factory, trade contract and proforma invoice on hand. I am not sure what other core documents are needed, and I am more worried that the early transfer of title under EXW may not meet the "four flows consistency" requirement for tax refund. If there is an error in the declaration, we will not only fail to get the tax refund, but may also trigger tax correspondence verification or even fines. I have been staying up late to look up information recently but still have no clue, so I would like to ask in detail how to declare EXW export tax refund, and what details and risk mitigation points must be paid attention to? 

## Answers
                            
### Answer 1 — Best Answer

First，for pre-document review details，three types of core materials shall be checked with priority: First，the **special input VAT invoice** issued by the factory，to ensure that the product name，specification and quantity fully match those on the customs declaration form，and the remark column of the invoice shall indicate information related to the export of goods. Second，the **export goods customs declaration form (tax refund copy)** provided by the freight forwarder，the remark column shall clearly indicate the "EXW" trade term，and the operating unit shall be the foreign trade enterprise applying for tax refund. Third，logistics documents such as freight forwarder's delivery note and ocean bill of lading，which shall reflect the complete chain of title transfer from the factory to the overseas purchaser.

For the connection of core nodes，three key actions shall be completed simultaneously: First，obtain the tax refund copy of the customs declaration form from the freight forwarder within 10 working days after customs declaration，and enter it into the export tax refund declaration system simultaneously. Second，confirm that the input VAT invoice has completed VAT certification，and the "four flows consistency" is traceable - under the EXW model，the goods flow shall be supported by delivery notes and logistics tracks. Third，complete the pre-declaration and formal declaration strictly within the declaration period (from the next month of export to the VAT declaration period in April of the following year).

The contingency plan shall cover two types of common problems: If the remark column of the customs declaration form does not indicate "EXW"，contact the freight forwarder to apply for form modification within 30 days after customs declaration，and submit the trade contract and delivery note as supporting documents. If "document information mismatch" occurs in the pre-declaration，check the differences in code and quantity between the input invoice and customs declaration form within 5 working days，and submit the corrected declaration data.

For the final compliance implementation，document filing shall be completed within 15 days after the formal declaration. The filing materials include copies of contracts，customs declaration forms，bills of lading and input invoices，and the retention period shall be no less than 5 years to ensure that the full business chain can be completely traced during tax inspection.

**status:** accepted
**Author:** Evelyn Li
**Date:** 2026-05-12

### Answer 2

Under the EXW model, the operating unit on the customs declaration form must be explicitly the foreign trade enterprise applying for tax refund, the consignee unit shall fill in the full name and address of the overseas final purchaser, the remark column must indicate the "EXW" trade term, and supplement the specific address of the factory and the number of the freight forwarder's delivery voucher. If the freight forwarder's name is mistakenly used as the operating unit during customs declaration, immediately submit the entrusted customs declaration agreement signed between the foreign trade enterprise and the freight forwarder and the title transfer certificate issued by the factory to the customs to apply for form modification, otherwise the customs declaration form cannot be used as a tax refund voucher.

The form modification application shall be submitted within 30 days after the issuance of the customs declaration form. The customs will not accept applications overdue, which will directly lead to the stagnation of tax refund declaration. In addition, the commodity code, quantity and FOB price on the customs declaration form shall be fully consistent with those on the input invoice and contract. If there is any difference, explain to the customs and adjust it in advance to avoid subsequent tax correspondence verification.

**status:** suggested
**Author:** Grace Wang
**Date:** 2026-05-12

### Answer 3

Under the EXW model, the traceability of logistics tracks is one of the core supporting evidences for tax refund declaration. Three types of logistics documents shall be retained throughout the process: First, the delivery note issued by the freight forwarder when picking up goods from the factory, which shall indicate the factory name, goods details and delivery date. Second, the LCL or FCL warehouse receipt, which clarifies the port where the goods are stored and the name and voyage of the loading ship. Third, the ocean or air bill of lading, which shall show the overseas purchaser as the consignee.

If the goods are transshipped to another port, timely obtain the transshipment certificate issued by the transit port agent and supplement it to the tax refund filing materials to avoid the tax authority questioning the authenticity of the goods flow due to incomplete logistics tracks. In addition, ensure that the quantity and specification of goods on the logistics documents fully match those on the customs declaration form and input invoice. If there is LCL cargo separation, obtain the cargo separation detail list issued by the LCL company to clarify the goods batch corresponding to the tax refund.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-05-12

### Answer 4

In markets such as the EU that adopt the VAT deferral policy, import VAT deferral can be applied for simultaneously under the EXW model to reduce the capital occupation cost of enterprises, but it is necessary to ensure that the declaration subject of VAT deferral is consistent with the declaration subject of tax refund. The tax rate of the input invoice shall match the tax refund rate of the exported goods.

If there is a difference between the levy rate and the refund rate, complete the input tax transfer operation within the VAT declaration period to avoid triggering tax warning. The tax calculation basis for export tax refund under EXW is the FOB price on the customs declaration form. The ex-factory price of the factory shall be converted into FOB price.

The conversion shall include customs declaration fees, port charges and other directly export-related fees charged by the freight forwarder, but shall not include overseas transportation fees. The conversion rules shall strictly follow the latest regulations of the tax authority to avoid deviation in the calculation of tax refund amount due to wrong tax calculation basis.

**status:** suggested
**Author:** Cindy Chen
**Date:** 2026-05-11

### Answer 5

Under the EXW model, the fund flow for export tax refund shall meet the requirement of being paid directly from the overseas purchaser to the account of the foreign trade enterprise applying for tax refund. If settlement is made through a third-party payment platform due to special circumstances, a copy of the cross-border payment license of the third-party payment institution and payment details shall be provided to prove the legality of the source of funds. The amount of the fund flow shall be consistent with the amount on the contract, input invoice and customs declaration form.

If there is an advance payment, the proportion of advance payment and payment time shall be clearly indicated in the trade contract, and the bank slip shall be retained as supporting evidence. In addition, foreign exchange collection shall be completed within 180 days after the export goods are declared at customs, and the foreign exchange collection information shall be declared in the foreign exchange monitoring system in a timely manner. If foreign exchange collection cannot be completed on time due to special circumstances, apply to the tax authority for delayed foreign exchange collection filing to avoid the rejection of tax refund declaration due to overdue foreign exchange collection.

**status:** suggested
**Author:** Jason Wu
**Date:** 2026-05-11

### Answer 6

Three core clauses related to tax refund shall be clearly agreed in the EXW trade contract: First, the factory shall cooperate with the foreign trade enterprise to provide true and valid special input VAT invoices and goods ex-factory certificates. If the tax refund fails due to false documents provided by the factory, the factory shall bear all losses.

Second, the time point of title transfer shall be clearly defined as "upon delivery at the factory", and the specific delivery address shall be indicated to avoid disputes over title ownership affecting the tax authority's determination of the goods flow. Third, the freight forwarder shall provide core documents such as the tax refund copy of the export goods customs declaration form and logistics delivery note within 10 working days after customs declaration.

If the tax refund is delayed due to the delay or loss of documents by the freight forwarder, the freight forwarder shall bear the corresponding liability for breach of contract. In addition, the contract shall supplement the agreement on the reissue process after the loss of documents to ensure that alternative vouchers can be obtained quickly in case of abnormality.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-05-11

### Answer 7

Under the EXW model, if the goods are inspected by the customs on site during transportation from the factory pick-up to the export port, the inspection record form issued by the customs and photos of the goods inspection shall be retained throughout the process as core supporting materials for the goods flow.

If it is found during inspection that the specification and quantity of the goods are inconsistent with the contents declared on the customs declaration form, immediately apply to the customs for adjusting the customs declaration form information, and simultaneously require the factory to update the corresponding details of the input invoice to avoid triggering tax correspondence verification due to document mismatch during subsequent tax refund declaration. In addition, if sampling inspection is required during inspection, the inspection notice and inspection report issued by the customs shall be retained and supplemented to the tax refund filing materials to ensure that the tax authority can fully trace the compliance of the goods.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-05-11

### Answer 8

If dangerous goods are exported under the EXW model, UN dangerous goods packaging certificate, MSDS report and packaging inspection qualification certificate shall be provided as supplementary supporting materials for tax refund filing to ensure that the tax authority recognizes the compliance of the export of goods. The goods details on the packaging documents (such as product name, quantity, packaging specification) shall be fully consistent with those on the customs declaration form and input invoice.

If there are multiple packaging batches, the tax refund declaration details corresponding to each batch shall be clearly indicated. If wooden packaging is used, the official fumigation certificate shall be provided to avoid cargo detention at the port or customs clearance failure due to non-compliant wooden packaging, which will further delay the time node of tax refund declaration - if the exported goods have not completed customs clearance more than 90 days after customs declaration, the tax refund declaration process cannot be started normally.

**status:** suggested
**Author:** Andy Guo
**Date:** 2026-05-11

### Answer 9

The core of the "four flows consistency" verification for export tax refund under the EXW model is: the contract flow is the trade contract signed between the foreign trade enterprise and the overseas purchaser, the fund flow is the bank slip of the payment directly made by the overseas purchaser to the foreign trade enterprise, the invoice flow is the special input VAT invoice issued by the factory to the foreign trade enterprise, and the goods flow is the complete logistics documents (delivery note, bill of lading, etc.) from the factory to the overseas purchaser. The original copies or electronic scanned copies of all documents shall be filed and retained for no less than 5 years to ensure that the full business chain can be completely traced during tax audit.

If there is entrusted customs declaration, the entrusted customs declaration agreement signed between the foreign trade enterprise and the freight forwarder shall be provided as supplementary supporting material for "four flows consistency". In addition, pre-declaration self-inspection shall be completed before formal declaration, focusing on checking the accuracy of commodity code, tax calculation basis and foreign exchange collection information, to avoid triggering tax correspondence verification due to declaration errors.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-05-11

### Answer 10

If an enterprise switches from the EXW model to other trade terms (such as FOB, CIF), the tax calculation basis for export tax refund shall be adjusted simultaneously - the tax calculation basis for EXW is the FOB price converted from the ex-factory price plus customs declaration, port charges and other fees, while the FOB model directly takes the FOB price on the customs declaration form as the tax calculation basis. The connection efficiency of supply chain nodes shall be optimized, and a real-time communication mechanism among factories, freight forwarders and financial and tax departments shall be established to ensure that customs declaration forms, input invoices and logistics documents can be synchronized to the financial and tax departments as soon as possible, so as to avoid delaying the time node of tax refund declaration.

The full-chain service of foreign trade agency companies can be used to simplify the tax refund declaration process - the agency company can provide one-stop services including document review, pre-declaration and formal declaration, to improve the accuracy and efficiency of tax refund declaration. In addition, the time for foreign exchange collection shall be planned in advance to ensure that foreign exchange collection is completed within 180 days after export, so as to avoid affecting the compliance of tax refund declaration.

**status:** suggested
**Author:** Kevin Lin
**Date:** 2026-05-11

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