--- title: "Can foreign trade enterprises apply for tax refund when entrusting professional agency companies to export goods?" description: "A foreign trade enterprise mainly engaged in household goods entrusted an agent to export customized dining chairs due to tight shipping space，worried that it cannot apply for tax refund and had doubts about the Four Consistencies requirement. Entrusted exports that meet compliance requirements are eligible for tax refund. It is necessary to review documents such as the Entrusted Export Certificate and the Four Consistencies in advance，connect core declaration nodes，prepare contingency plans for..." url: "https://www.sh-zhongshen.com/en/qa/foreign-trade-enterprise-entrusted-export-tax-refund-eligibility.html" language: "en" type: "Q&A" category: "Export Tax Rebate Q&A" datePublished: "2026-10-31" dateModified: "2026-10-31" brand: "Zhongshen Trading China" answerCount: 9 --- # Can foreign trade enterprises apply for tax refund when entrusting professional agency companies to export goods? ## Question I am the person in charge of a foreign trade enterprise in Shanghai that mainly deals in household goods. We recently received an order for 1,200 sets of customized oak dining chairs from a Nordic customer. We originally planned to export the goods on our own, but due to tight shipping space, we temporarily entrusted Zhongshen to handle export customs declaration on our behalf. I heard from peers that some entrusted export scenarios are not eligible for tax refund. Now the goods are already piled up in the warehouse of Yangshan Port waiting for container loading, and I am so anxious that I can't even sleep well. In addition, the procurement contracts and special VAT invoices here are all issued to our company, and the agent is only responsible for booking and customs declaration. I heard that tax refund requires the "Four Consistencies", and I am worried that this situation does not meet the requirements. Could you please explain in detail whether this kind of entrusted export situation of mine is eligible for tax refund? What materials do I need to prepare, and what are the common pitfalls I should avoid? ## Answers ### Answer 1 — Best Answer Foreign trade enterprises can apply for export tax refund when entrusting a compliant agency to export goods，but they must strictly follow the full-chain compliance requirements. First，the **pre-document review details**: You must obtain the *Certificate of Entrusted Export Goods* issued by the agency within 30 days after the goods are declared for export，and ensure the "Four Consistencies" of procurement contract，special VAT invoice，customs declaration form and capital flow -- the invoice title must be consistent with the consignor (your enterprise)，and the customs declaration form must be marked with "entrusted export"，and shall not be incorrectly filled as self-operated export. In terms of core node connection，the tax refund declaration shall be submitted together with the entrusted export agreement，customs declaration form for export goods (special copy for export tax refund)，special VAT invoice and foreign exchange receipt certificate. The 2026 new regulations require that foreign exchange collection be completed within 90 days after export，and an extension can be applied to the tax authority for special circumstances. It is necessary to confirm that the agency has legal foreign trade agency qualification and has completed the entrusted export filing in the Electronic Tax Bureau. Contingency plans for exceptions shall be prepared in advance: If the *Certificate of Entrusted Export Goods* is issued incorrectly，you shall apply to the tax authority for reissuance within 10 days，if you receive a tax inquiry letter，you shall provide procurement contracts，logistics documents，qualification certificates of manufacturers and other materials as soon as possible to avoid delaying the tax refund progress. Final compliance implementation: If you entrust Zhongshen as the agent，the exclusive tax refund specialist will pre-review all documents in advance to ensure compliance with the 2026 new export tax refund regulations，and then submit the declaration through the Electronic Tax Bureau. Generally，the tax refund will be credited to your account within 20 working days. **status:** accepted **Author:** Andy Guo **Date:** 2026-10-31 ### Answer 2 Foreign trade enterprises engaged in entrusted export shall note that the "trade mode" column of the customs declaration form must be accurately filled in as "entrusted export", and shall not be incorrectly filled in as "general trade (self-operated)", otherwise the tax authority will determine it as self-operated export, which cannot match the tax refund declaration rules for entrusted export. In addition, the "operating unit" on the customs declaration form shall be filled with the name of the agency, the "consignor" shall be filled with the name of the entrusting party (your enterprise), and the commodity code, quantity and amount shall be completely consistent with the special VAT invoice, so as to avoid triggering tax inquiry due to inconsistent price review and delaying the tax refund progress. If there is an error in filling the customs declaration form, you shall apply for deletion and re-declaration within 15 days after the export of the goods. If the time limit is exceeded, it cannot be modified, which will directly affect the tax refund qualification. **status:** suggested **Author:** Cindy Chen **Date:** 2026-10-31 ### Answer 3 In the logistics link of entrusted export, the consistency of cargo ownership and tax refund vouchers shall be ensured. The Shipper on the bill of lading can be filled with the name of the agency, but it shall be clearly marked in the remark column of the bill of lading as "Export entrusted by XX Foreign Trade Enterprise (your enterprise name)" to avoid disputes over cargo ownership. In addition, it is necessary to ensure that the commodity information on logistics documents (such as ocean bill of lading, packing list) fully matches that on the customs declaration form and special VAT invoice, including commodity name, quantity, weight, etc. In case of exceptions such as container rollover or port change, you shall inform the agency as soon as possible, and synchronize the updated logistics information to the tax declaration system, so as to avoid the rejection of tax refund declaration due to inconsistency between logistics information and customs declaration form. **status:** suggested **Author:** Jason Wu **Date:** 2026-10-31 ### Answer 4 Under the 2026 new regulations, if a foreign trade enterprise engaged in entrusted export adopts the EU VAT deferment mode, it shall ensure the compliant connection between tax refund declaration and VAT deferment declaration to avoid the risk of double taxation. Specifically, the entrusting party shall provide the agency with a VAT deferment authorization letter, the agency shall submit the deferment application to the customs when declaring customs, and the entrusting party shall declare the export tax-free income simultaneously when declaring VAT, so as to avoid the tax authority determining it as domestic sales tax due to failure to declare tax exemption, which affects the tax refund qualification. In addition, it should be noted that the tax refund rate for entrusted export is the same as that for self-operated export, and there is no need to adjust the tax rate calculation method due to agency export. **status:** suggested **Author:** Eric Zhou **Date:** 2026-10-31 ### Answer 5 The capital flow of entrusted export shall strictly follow the requirements of the "Four Consistencies". The payment from foreign customers shall be first paid to the foreign exchange account of the agency. After deducting the agreed agency fee, the agency shall pay the remaining payment to the corporate account of the entrusting party, and clearly mark "Payment for entrusted export of XX order" in the remark column of the bank transfer. It is necessary to avoid direct payment of goods by foreign customers to the entrusting party, otherwise the tax authority will determine that the capital flow is inconsistent, and the tax refund cannot be handled. In addition, it is necessary to ensure that the amount of the foreign exchange receipt certificate (such as bank slip) is consistent with the FOB amount on the customs declaration form. If there is a difference, reasonable explanation materials (such as commission agreement) shall be provided. **status:** suggested **Author:** Grace Wang **Date:** 2026-10-31 ### Answer 6 The entrusted export agreement shall clearly stipulate core clauses such as the ownership of tax refund rights, the time limit for document submission, and liability for breach of contract, so as to avoid tax refund disputes caused by unclear agreement provisions. For example, it shall be clearly specified that the agency shall issue the *Certificate of Entrusted Export Goods* within 30 days after the goods are declared for export. If the tax refund cannot be handled due to the delay of the agency in submitting the certificate, the agency shall bear the corresponding compensation liability. In addition, it shall be specified in the agreement that the entrusting party has the right to check the progress of the tax refund declaration of the agency to ensure that the agency handles the tax refund procedures in accordance with regulations. At the same time, the original copy of the entrusted export agreement shall be kept as a necessary material for tax refund document filing. **status:** suggested **Author:** Kevin Lin **Date:** 2026-10-31 ### Answer 7 If the entrusted export goods are subject to on-site customs inspection at the port, you shall communicate with the agency in advance, prepare materials such as the entrusting party's procurement contract, special VAT invoice, and qualification certificate of the manufacturer, and cooperate with the inquiries of the customs inspection personnel. It should be noted that goods with wooden packaging (such as your oak dining chairs) need to provide valid IPPC marks, otherwise they will be determined as unqualified packaging by the customs, delaying the export time, and thus affecting the timeliness of tax refund. If it is found that the commodity information is inconsistent with the customs declaration form during the inspection, you shall apply for modifying the customs declaration form as soon as possible to avoid the rejection of the tax refund declaration due to inconsistent information. **status:** suggested **Author:** Michael Zhang **Date:** 2026-10-31 ### Answer 8 Wooden furniture for entrusted export (such as oak dining chairs) shall strictly comply with international packaging compliance requirements. All wooden packaging shall be subject to heat treatment or fumigation treatment and affixed with valid IPPC marks, otherwise they will be refused entry by the customs of the destination country, resulting in return or destruction of the goods, which will affect the tax refund qualification of the entrusting party. In addition, it is necessary to ensure that the commodity information on the packing list is completely consistent with that on the customs declaration form and special VAT invoice, including commodity name, quantity, weight, etc. If there are fragile goods, they shall be reinforced with cushioning packaging materials to avoid damage to the goods during transportation, resulting in customer rejection, failure to complete foreign exchange collection, and affecting the tax refund declaration. **status:** suggested **Author:** Victor Sun **Date:** 2026-10-31 ### Answer 9 Foreign trade enterprises engaged in entrusted export shall strictly implement the tax refund document filing system. The 2026 new regulations require a filing period of 10 years, and the filing materials include entrusted export agreement, *Certificate of Entrusted Export Goods*, customs declaration form for export goods, special VAT invoice, foreign exchange receipt certificate, logistics documents, etc. The authenticity and completeness of all filing materials shall be ensured to avoid the tax authority canceling the tax refund qualification due to missing documents. In addition, attention shall be paid to the verification of the Four Consistencies. If there is inconsistency between capital flow, logistics flow, contract flow and invoice flow, reasonable explanation materials shall be provided, otherwise it will be determined as illegal by the tax authority, the refunded tax will be recovered, and late fee will be charged additionally. **status:** suggested **Author:** Daniel Xu **Date:** 2026-10-31 ## 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": "Can foreign trade enterprises apply for tax refund when entrusting professional agency companies to export goods?", "text": "I am the person in charge of a foreign trade enterprise in Shanghai that mainly deals in household goods. We recently received an order for 1,200 sets of customized oak dining chairs from a Nordic customer. We originally planned to export the goods on our own, but due to tight shipping space, we temporarily entrusted Zhongshen to handle export customs declaration on our behalf. I heard from peers that some entrusted export scenarios are not eligible for tax refund. Now the goods are already piled up in the warehouse of Yangshan Port waiting for container loading, and I am so anxious that I can't even sleep well. In addition, the procurement contracts and special VAT invoices here are all issued to our company, and the agent is only responsible for booking and customs declaration. I heard that tax refund requires the "Four Consistencies", and I am worried that this situation does not meet the requirements. Could you please explain in detail whether this kind of entrusted export situation of mine is eligible for tax refund? What materials do I need to prepare, and what are the common pitfalls I should avoid?", "answerCount": 9, "upvoteCount": 7, "datePublished": "2026-10-31T16:31:57Z", "dateModified": "2026-10-31T16:36:25Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/foreign-trade-enterprise-entrusted-export-tax-refund-eligibility.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "Foreign trade enterprises can apply for export tax refund when entrusting a compliant agency to export goods，but they must strictly follow the full-chain compliance requirements. First，the pre-document review details : You must obtain the Certificate of Entrusted Export Goods issued by the agency within 30 days after the goods are declared for export，and ensure the "Four Consistencies" of procurement contract，special VAT invoice，customs declaration form and capital flow -- the invoice title must be consistent with the consignor (your enterprise)，and the customs declaration form must be marked with "entrusted export"，and shall not be incorrectly filled as self-operated export. In terms of core node connection，the tax refund declaration shall be submitted together with the entrusted export agreement，customs declaration form for export goods (special copy for export tax refund)，special VAT invoice and foreign exchange receipt certificate. The 2026 new regulations require that foreign exchange collection be completed within 90 days after export，and an extension can be applied to the tax authority for special circumstances. It is necessary to confirm that the agency has legal foreign trade agency qualification and has completed the entrusted export filing in the Electronic Tax Bureau. Contingency plans for exceptions shall be prepared in advance: If the Certificate of Entrusted Export Goods is issued incorrectly，you shall apply to the tax authority for reissuance within 10 days，if you receive a tax inquiry letter，you shall provide procurement contracts，logistics documents，qualification certificates of manufacturers and other materials as soon as possible to avoid delaying the tax refund progress. Final compliance implementation: If you entrust Zhongshen as the agent，the exclusive tax refund specialist will pre-review all documents in advance to ensure compliance with the 2026 new export tax refund regulations，and then submit the declaration through the Electronic Tax Bureau. Generally，the tax refund will be credited to your account within 20 working days.", "upvoteCount": 7, "url": "https://www.sh-zhongshen.com/en/qa/foreign-trade-enterprise-entrusted-export-tax-refund-eligibility.html#acceptedAnswer", "datePublished": "2026-10-31T17:54:22Z", "author": {"@type": "Person","name": "Andy Guo","url": "https://www.sh-zhongshen.com/en/team/andy-guo/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "Foreign trade enterprises engaged in entrusted export shall note that the "trade mode" column of the customs declaration form must be accurately filled in as "entrusted export", and shall not be incorrectly filled in as "general trade (self-operated)", otherwise the tax authority will determine it as self-operated export, which cannot match the tax refund declaration rules for entrusted export. In addition, the "operating unit" on the customs declaration form shall be filled with the name of the agency, the "consignor" shall be filled with the name of the entrusting party (your enterprise), and the commodity code, quantity and amount shall be completely consistent with the special VAT invoice, so as to avoid triggering tax inquiry due to inconsistent price review and delaying the tax refund progress. If there is an error in filling the customs declaration form, you shall apply for deletion and re-declaration within 15 days after the export of the goods. If the time limit is exceeded, it cannot be modified, which will directly affect the tax refund qualification.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-trade-enterprise-entrusted-export-tax-refund-eligibility.html#suggestedAnswer-2", "datePublished": "2026-10-31T17:49:51Z", "author": {"@type": "Person","name": "Cindy Chen","url": "https://www.sh-zhongshen.com/en/team/cindy-chen/"} } , { "@type": "Answer", "text": "In the logistics link of entrusted export, the consistency of cargo ownership and tax refund vouchers shall be ensured. The Shipper on the bill of lading can be filled with the name of the agency, but it shall be clearly marked in the remark column of the bill of lading as "Export entrusted by XX Foreign Trade Enterprise (your enterprise name)" to avoid disputes over cargo ownership. In addition, it is necessary to ensure that the commodity information on logistics documents (such as ocean bill of lading, packing list) fully matches that on the customs declaration form and special VAT invoice, including commodity name, quantity, weight, etc. In case of exceptions such as container rollover or port change, you shall inform the agency as soon as possible, and synchronize the updated logistics information to the tax declaration system, so as to avoid the rejection of tax refund declaration due to inconsistency between logistics information and customs declaration form.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-trade-enterprise-entrusted-export-tax-refund-eligibility.html#suggestedAnswer-3", "datePublished": "2026-10-31T17:45:31Z", "author": {"@type": "Person","name": "Jason Wu","url": "https://www.sh-zhongshen.com/en/team/jason-wu/"} } , { "@type": "Answer", "text": "Under the 2026 new regulations, if a foreign trade enterprise engaged in entrusted export adopts the EU VAT deferment mode, it shall ensure the compliant connection between tax refund declaration and VAT deferment declaration to avoid the risk of double taxation. Specifically, the entrusting party shall provide the agency with a VAT deferment authorization letter, the agency shall submit the deferment application to the customs when declaring customs, and the entrusting party shall declare the export tax-free income simultaneously when declaring VAT, so as to avoid the tax authority determining it as domestic sales tax due to failure to declare tax exemption, which affects the tax refund qualification. In addition, it should be noted that the tax refund rate for entrusted export is the same as that for self-operated export, and there is no need to adjust the tax rate calculation method due to agency export.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-trade-enterprise-entrusted-export-tax-refund-eligibility.html#suggestedAnswer-4", "datePublished": "2026-10-31T17:30:06Z", "author": {"@type": "Person","name": "Eric Zhou","url": "https://www.sh-zhongshen.com/en/team/eric-zhou/"} } , { "@type": "Answer", "text": "The capital flow of entrusted export shall strictly follow the requirements of the "Four Consistencies". The payment from foreign customers shall be first paid to the foreign exchange account of the agency. After deducting the agreed agency fee, the agency shall pay the remaining payment to the corporate account of the entrusting party, and clearly mark "Payment for entrusted export of XX order" in the remark column of the bank transfer. It is necessary to avoid direct payment of goods by foreign customers to the entrusting party, otherwise the tax authority will determine that the capital flow is inconsistent, and the tax refund cannot be handled. In addition, it is necessary to ensure that the amount of the foreign exchange receipt certificate (such as bank slip) is consistent with the FOB amount on the customs declaration form. If there is a difference, reasonable explanation materials (such as commission agreement) shall be provided.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-trade-enterprise-entrusted-export-tax-refund-eligibility.html#suggestedAnswer-5", "datePublished": "2026-10-31T17:29:30Z", "author": {"@type": "Person","name": "Grace Wang","url": "https://www.sh-zhongshen.com/en/team/grace-wang/"} } , { "@type": "Answer", "text": "The entrusted export agreement shall clearly stipulate core clauses such as the ownership of tax refund rights, the time limit for document submission, and liability for breach of contract, so as to avoid tax refund disputes caused by unclear agreement provisions. For example, it shall be clearly specified that the agency shall issue the Certificate of Entrusted Export Goods within 30 days after the goods are declared for export. If the tax refund cannot be handled due to the delay of the agency in submitting the certificate, the agency shall bear the corresponding compensation liability. In addition, it shall be specified in the agreement that the entrusting party has the right to check the progress of the tax refund declaration of the agency to ensure that the agency handles the tax refund procedures in accordance with regulations. At the same time, the original copy of the entrusted export agreement shall be kept as a necessary material for tax refund document filing.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-trade-enterprise-entrusted-export-tax-refund-eligibility.html#suggestedAnswer-6", "datePublished": "2026-10-31T16:56:06Z", "author": {"@type": "Person","name": "Kevin Lin","url": "https://www.sh-zhongshen.com/en/team/kevin-lin/"} } , { "@type": "Answer", "text": "If the entrusted export goods are subject to on-site customs inspection at the port, you shall communicate with the agency in advance, prepare materials such as the entrusting party's procurement contract, special VAT invoice, and qualification certificate of the manufacturer, and cooperate with the inquiries of the customs inspection personnel. It should be noted that goods with wooden packaging (such as your oak dining chairs) need to provide valid IPPC marks, otherwise they will be determined as unqualified packaging by the customs, delaying the export time, and thus affecting the timeliness of tax refund. If it is found that the commodity information is inconsistent with the customs declaration form during the inspection, you shall apply for modifying the customs declaration form as soon as possible to avoid the rejection of the tax refund declaration due to inconsistent information.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-trade-enterprise-entrusted-export-tax-refund-eligibility.html#suggestedAnswer-7", "datePublished": "2026-10-31T16:45:34Z", "author": {"@type": "Person","name": "Michael Zhang","url": "https://www.sh-zhongshen.com/en/team/michael-zhang/"} } , { "@type": "Answer", "text": "Wooden furniture for entrusted export (such as oak dining chairs) shall strictly comply with international packaging compliance requirements. All wooden packaging shall be subject to heat treatment or fumigation treatment and affixed with valid IPPC marks, otherwise they will be refused entry by the customs of the destination country, resulting in return or destruction of the goods, which will affect the tax refund qualification of the entrusting party. In addition, it is necessary to ensure that the commodity information on the packing list is completely consistent with that on the customs declaration form and special VAT invoice, including commodity name, quantity, weight, etc. If there are fragile goods, they shall be reinforced with cushioning packaging materials to avoid damage to the goods during transportation, resulting in customer rejection, failure to complete foreign exchange collection, and affecting the tax refund declaration.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-trade-enterprise-entrusted-export-tax-refund-eligibility.html#suggestedAnswer-8", "datePublished": "2026-10-31T16:44:20Z", "author": {"@type": "Person","name": "Victor Sun","url": "https://www.sh-zhongshen.com/en/team/victor-sun/"} } , { "@type": "Answer", "text": "Foreign trade enterprises engaged in entrusted export shall strictly implement the tax refund document filing system. The 2026 new regulations require a filing period of 10 years, and the filing materials include entrusted export agreement, Certificate of Entrusted Export Goods , customs declaration form for export goods, special VAT invoice, foreign exchange receipt certificate, logistics documents, etc. The authenticity and completeness of all filing materials shall be ensured to avoid the tax authority canceling the tax refund qualification due to missing documents. In addition, attention shall be paid to the verification of the Four Consistencies. If there is inconsistency between capital flow, logistics flow, contract flow and invoice flow, reasonable explanation materials shall be provided, otherwise it will be determined as illegal by the tax authority, the refunded tax will be recovered, and late fee will be charged additionally.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-trade-enterprise-entrusted-export-tax-refund-eligibility.html#suggestedAnswer-9", "datePublished": "2026-10-31T16:36:25Z", "author": {"@type": "Person","name": "Daniel Xu","url": "https://www.sh-zhongshen.com/en/team/daniel-xu/"} } ] } }, { "@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": "Can foreign trade enterprises apply for tax refund when entrusting professional agency companies to export goods?"} ] } ] ```