Can manufacturing enterprises normally enjoy export tax refunds under the agency export model?

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  • Aug 23, 2026 at 05:59
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I am the head of a small and medium-sized garment manufacturing enterprise. We recently received an order from Europe, and since we do not have the right to self-operate exports, we plan to cooperate with a foreign trade agent.

I heard from peers earlier that tax refunds may not be obtained for agency exports, which makes me very worried -- the profit margin of this order is already very thin, and if we cannot get the tax refund, we will basically make no profit from this deal. I would like to ask: Can we really enjoy tax refunds for agency exports?

If yes, is the tax refund subject the principal or the agent? What documents do we need to prepare? What new policies in 2026 should we pay attention to to avoid pitfalls?

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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

Enterprises meeting the requirements can normally enjoy export tax refunds under the agency export model，and the core rules must be clarified first: The 2026 policy clearly stipulates that the principal (manufacturing enterprise) is the tax refund subject，and the agent only assumes the responsibility of assisting in declaration and providing compliant documents.

Two key points must be controlled in pre-document review: First，the principal shall provide a special VAT invoice with the product name and HS code completely consistent with those on the customs declaration form，and the remarks column of the invoice shall indicate "entrusted agency export" and the agency agreement number，Second，the agent shall apply for the electronic customs declaration form within 3 working days after the goods are exported，and synchronize it to the principal's tax declaration system. If there are discrepancies in the documents，corrections shall be completed within 72 hours，otherwise the time limit for tax refund declaration will be affected.

Connection process for core nodes: The agent shall issue the *Certificate of Goods Exported via Agency* within 10 days after the goods depart from the port，and file it via the electronic tax bureau，The principal shall complete the "exemption，credit and refund" tax declaration with the certificate and relevant documents from the month following the export of the goods to April 30 of the next year. A new requirement added in 2026 stipulates that the agency agreement must be electronically filed via the "Single Window" of the General Administration of Customs，and unfiled agreements cannot be used as tax refund vouchers.

Abnormal contingency handling: If the synchronization of customs declaration information is delayed，the agent may apply to the customs for "urgent push"，If the invoice information does not match，it is necessary to coordinate with the principal to reissue the invoice and synchronize the red-letter invoice for offsetting. In addition，the error between the received foreign exchange amount and the customs declaration amount shall be controlled within 5%. A reasonable explanation shall be provided for the excess part，otherwise the tax authority will suspend the tax refund.

The final compliance implementation needs to ensure "consistency of three flows": the capital flow (foreign exchange receipt records of the principal)，the goods flow (logistics bill of lading)，and the document flow (customs declaration form and invoice) must be completely matched. The agent shall keep all documents for future reference for at least 5 years，and the principal shall regularly check the information in the tax system to avoid tax refund failure caused by data disconnection.

Reference: I/E Declaration Agency Tax Rebate SOP | Practical Guide from Document Compliance to Tax Planning
Cindy Chen
Cindy ChenYears of service：3Customer Rating：5.0

Key Account ManagerStart a Chat

The accuracy of the customs declaration form is the core of agency export tax refund. After the integration of customs clearance in 2026, the electronic information of the customs declaration form will be synchronized to the tax system in real time. If the "trade mode" column is not filled with "entrusted agency export", the tax refund declaration will directly fail.

In addition, the HS code must be completely consistent with that on the VAT invoice, and code discrepancies will be judged as document non-conformity. It is recommended to confirm the accuracy of the HS code before customs declaration, and indicate the agency agreement number in the remarks column to facilitate tax verification.

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

Trade Risk Control ManagerStart a Chat

The control of cargo ownership in the logistics link affects the tax refund progress. When exporting via entrusted agency, the bill of lading shall indicate "the principal is the cargo owner" to avoid cargo ownership disputes caused by the agent being the consignee on the bill of lading. The new 2026 regulation requires that the sea bill of lading shall be telex released or the original copy shall be delivered within 7 days.

Delayed delivery will delay the application for the customs declaration form, which in turn affects the tax refund declaration. Clear customs in time after the goods arrive at the port to ensure that the logistics documents are consistent with the customs declaration information, so as to provide valid vouchers for tax refund.

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

Customs Declaration & Compliance ExpertStart a Chat

Attention should be paid to tax base confirmation for agency export tax refund. The new 2026 VAT regulation clearly stipulates that the tax refund base for the principal is the tax-exclusive amount on the invoice, and the agency fee shall be invoiced separately without confusion.

Small and micro enterprises can enjoy the tax refund acceleration policy, and the agent shall assist in providing the small and micro enterprise certificate. In addition, exchange gain shall be included in the taxable income to avoid tax risks.

Evelyn Li
Evelyn LiYears of service：3Customer Rating：5.0

Cross-border Compliance SupervisorStart a Chat

Compliance of foreign exchange receipt and payment is the prerequisite for tax refund. After the optimization of the CIPS system in 2026, the principal shall receive foreign exchange through the agent's foreign exchange account, and the error between the received foreign exchange amount and the customs declaration amount shall not exceed 5%.

The agent shall settle the foreign exchange and transfer it to the principal's account within 3 days, and provide the foreign exchange settlement memo. The SWIFT message shall indicate "agency export foreign exchange receipt" to avoid being judged as abnormal foreign exchange receipt which affects the tax refund qualification.

Jason Wu
Jason WuYears of service：10Customer Rating：5.0

International Logistics & Supply Chain ManagerStart a Chat

The agency agreement shall clarify the tax refund responsibilities. The new 2026 regulation requires that the agreement stipulates the agent's assistance obligations, including providing export certificates and cooperating with verification, etc. If the tax refund is delayed due to the agent's failure to provide documents in time, the agent shall bear the compensation liability.

The agreement shall clarify the document storage responsibility, and the agent shall keep the documents for at least 5 years. It is recommended to add breach of contract clauses to protect the rights and interests of the principal.

Daniel Xu
Daniel XuYears of service：10Customer Rating：5.0

Director of Import & Export OperationsStart a Chat

The result of on-site inspection affects the tax refund qualification. If the goods are inspected by the customs, it is necessary to ensure that the goods are consistent with the customs declaration form.

Inconsistent goods will be judged as false export and the tax refund will be cancelled. The new 2026 regulation requires the agent to send a special person to cooperate with the inspection and provide a copy of the agreement.

If there is a code error, the customs declaration form shall be modified in time, otherwise the tax refund declaration will be affected. It is recommended to conduct pre-inspection before export to avoid problems.

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

Documentation SupervisorStart a Chat

Packaging compliance indirectly affects the tax refund process. The packaging of goods exported via agency shall meet the standards of the destination country.

Port detention or return caused by packaging problems will make verification impossible, which in turn affects the tax refund. Dangerous goods shall obtain UN packaging certification and indicate the certification number, and the packaging documents shall be consistent with the customs declaration form to ensure that the complete document flow supports the tax refund.

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

Supply Chain Management ExpertStart a Chat

Tax refund audit checks the consistency of four flows. The new 2026 regulation requires checking whether the capital flow, goods flow, document flow and contract flow are consistent.

Any inconsistency in any flow will be judged as violation and the tax refund will be recovered. It is recommended that the agent establish a four-flow verification mechanism, conduct internal audit before declaration, and provide documents in time during letter verification to avoid failure.

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

Trade Solutions ManagerStart a Chat

Supply chain optimization improves tax refund efficiency. The principal and the agent shall establish an integrated system to share document information and reduce communication costs.

The 2026 regulation requires agency enterprises to use an electronic document system to manage customs declaration forms, invoices, etc., to speed up the declaration process. Optimize logistics routes and choose direct shipping routes to shorten the export time, complete the tax refund declaration in advance, and improve the capital turnover rate.

Note: We respect all users' expressions; however, user comments represent their personal views only.

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