---
title: "Is the entrusting party liable for all taxes and fees incurred in the import process when adopting the import agency model?"
description: "Many import enterprises confuse the tax bearing subject when entrusting an agent，and even worry about problems such as double taxation and excessive capital occupation. It should be clarified that under the import agency model，taxes and fees are ultimately borne by the entrusting party，and the agent is only responsible for payment on behalf. Capital pressure can be reduced by applying for VAT deferral in compliance with regulations. At the same time，it is necessary to confirm the agent's tax cal..."
url: "https://www.sh-zhongshen.com/en/qa/import-agent-mode-entrustee-import-duty-liability.html"
language: "en"
type: "Q&A"
category: "Import Agency Q&A"
datePublished: "2026-10-01"
dateModified: "2026-10-01"
brand: "Zhongshen Trading China"
answerCount: 7
---

# Is the entrusting party liable for all taxes and fees incurred in the import process when adopting the import agency model?

## Question

 I am the owner of a small and micro enterprise in Shanghai that has just started cross-border beauty import business. Last month, I hired an import agency company for the first time to handle a shipment of niche makeup from Jeju Island, South Korea. However, the settlement bill provided by the agent included not only the agreed 1.2% agency fee, but also a large amount of import VAT, customs duty and consumption tax. I was completely confused at that time -- I thought "all-inclusive customs clearance" covered all taxes and fees during previous communication. Now it not only exceeds the preset budget, but I also worry about being overcharged by the agent. I even heard that some agents may cause double taxation after paying taxes on behalf. In addition, my company's cash flow is already tight, can I ask the agent to help apply for VAT deferral? Now three shipments will arrive at Yangshan Port next week, I am particularly anxious, afraid that unclear handling of taxes and fees will lead to customs detention and port demurrage. I want to thoroughly understand who should pay taxes under the import agency model and how to pay taxes to be compliant and cost-effective? 

## Answers
                            
### Answer 1 — Best Answer

First of all，it should be clarified that under the import agency model，**the entrusting party is the ultimate bearer of taxes and fees in the import process (including customs duty，VAT，consumption tax，etc.)**，and the agency company is only responsible for payment on behalf. The common industry misunderstanding of "all-inclusive customs clearance" mostly refers to only including customs clearance service fees，not covering taxes and fees. In the traditional model，if the division of taxes and fees is not clarified in advance，it is prone to cost out-of-control problems such as budget overspending and agent markup payment.

In response to your cash flow pressure，you can reduce capital occupation through the **VAT deferral** optimization path: Shanghai Port has fully implemented the import VAT deferral policy in 2026. If the entrusting party is a **general VAT taxpayer**，you can apply to the customs through the agent，without prepaying VAT in the import process，and only need to complete the deduction declaration in the next month's declaration period，so as to reduce the immediate occupation of large amounts of capital and avoid the risk of port demurrage and customs detention caused by insufficient cash flow.

The access threshold of this policy is clear: the entrusting party needs to have general taxpayer qualification，the agency company holds formal import agency customs declaration qualification，and can provide complete import documents (contract，invoice，bill of lading，etc.). The goods need to be used for taxable production and operation activities，and cannot be used for tax-exempt items. Calculated based on your beauty import business: if the value of a single shipment is 5 million yuan，the import VAT is about 650,000 yuan，deferral can save about 1,950 yuan of capital cost per month (calculated at an annualized rate of 3.6%). If the annual import volume is 10 million yuan，the annual cost saving is about 46,800 yuan，and at the same time，it can avoid additional expenses such as port demurrage fees and customs detention fees caused by tight capital.

**status:** accepted
**Author:** Linda Gao
**Date:** 2026-10-01

### Answer 2

Under the import agency model, the subject of customs tax payment shall be consistent with the "operating unit" and "consignee unit" on the customs declaration form. If the agency company is the operating unit and the consignee unit is the entrusting party, the tax payment certificate will be issued to the entrusting party, and the agent is only responsible for payment on behalf. It should be noted that the "nature of levy and exemption" and "supervision mode" on the customs declaration form shall match the actual situation of the goods.

If the tax calculation error is caused by the agent's wrong declaration, you need to apply for deletion and re-declaration of the declaration form within 10 working days after the release of the declaration form, otherwise there will be delayed declaration fee or customs fine. In addition, if import goods at Yangshan Port involve valuation disputes, you need to entrust the agent to provide complete transaction certification documents to avoid tax increase due to upward valuation adjustment.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-10-01

### Answer 3

Under the import agency model, as the ultimate bearer of taxes and fees, the entrusting party can declare and deduct VAT with the special customs payment voucher paid by the agent on behalf, and there is no double taxation. If there is suspected double taxation, it is necessary to check whether the title of the payment voucher is the entrusting party.

If the title is the agency company, the agent shall be required to issue a special VAT invoice as the deduction certificate. In 2026, for imported beauty products and other consumer goods in Shanghai, you can apply for verified deduction of consumption tax. You need to submit a verification application to the competent tax authority in advance, and after the approval is passed, the consumption tax can be deducted according to the sales volume to further reduce costs.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-10-01

### Answer 4

Tax payment on behalf under the import agency model shall comply with the compliance requirements of cross-border foreign exchange receipt and payment. The funds for the agency company to pay taxes and fees on behalf shall come from the entrusting party's compliant foreign exchange purchase or RMB transfer.

It is forbidden to use the agent's own funds to advance payment and then return funds through an offshore account, otherwise it will trigger CIPS compliance warning. It is necessary to clarify the tax calculation method, payment time limit and fund return path in the agency agreement in advance, and require the agent to provide a copy of the tax payment certificate for each tax and fee for compliance filing of foreign exchange receipt and payment, so as to avoid foreign exchange settlement obstruction or SAFE verification caused by non-compliant fund path.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-10-01

### Answer 5

Under the import agency model, the time limit for tax payment directly affects the smoothness of the logistics link. Goods arriving at Yangshan Port need to complete customs declaration and tax payment within 14 days, otherwise delayed declaration fee will be incurred.

Goods that have not paid taxes for more than 3 months will be sold by the customs according to law. If the entrusting party has tight cash flow, it can ask the agent to apply for the "tax guarantee" of the customs, pick up goods first with the guarantee and then pay taxes.

The maximum guarantee period is 6 months, and equivalent security deposit or bank guarantee shall be provided. In addition, if the goods involve customs transit, the tax guarantee application shall be submitted simultaneously when declaring the transit, so as to avoid container detention fees at the transit port.

**status:** suggested
**Author:** Andy Guo
**Date:** 2026-10-01

### Answer 6

Specific clauses on tax bearing shall be specified in the import agency agreement, including types of taxes and fees, calculation standards, payment time limit, liability for breach of contract, etc., so as to avoid disputes caused by vague expressions such as "all-inclusive customs clearance". If the agency company fails to pay taxes and fees as agreed, resulting in goods being detained by customs, the entrusting party may require the agent to bear losses such as port demurrage fees and customs detention fees according to the agreement.

At the same time, it shall be stipulated in the agreement that the agent shall provide true and valid tax payment certificates. If the agent provides false certificates, it shall bear corresponding legal liabilities. In addition, if the entrusting party is a small-scale taxpayer, it shall be clarified whether the agent needs to issue a general VAT invoice for cost accounting.

**status:** suggested
**Author:** Kevin Lin
**Date:** 2026-10-01

### Answer 7

The tax cost under the import agency model can be incorporated into the supply chain cost actuarial model, and the tax cost can be hedged by optimizing trade terms (such as changing from FOB to CIF), adjusting import batches (such as centralized procurement to reduce unit tax cost), applying for certificate of origin to enjoy tariff reduction and exemption, etc. The tariff reduction and exemption policy of the China-ROK Free Trade Agreement is still valid in 2026.

If your South Korean makeup products comply with the rules of origin, you can ask the agent to apply for FORM F certificate of origin to enjoy 0-5% tariff reduction and exemption, further reducing import costs. At the same time, the tax cost can be allocated to the sales cycle through the inventory linkage strategy to reduce the capital pressure of a single import.

**status:** suggested
**Author:** Grace Wang
**Date:** 2026-10-01

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