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Can Manufacturing Enterprises Entrusting Trade Agency for Export Apply for Export Tax Refund?
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I am the owner of a garment manufacturing enterprise. Recently I entrusted a trade agency to export an order to Europe for the first time.
The contract was signed between the agency and the overseas buyer, but we shipped the goods ourselves and we issued the invoice to the agency. Now my finance team asks me whether we are eligible for tax refund, and I am confused — should we apply for tax refund by ourselves or shall the agency do it?
I heard from a friend that tax refund for agency export is prone to problems, for example incomplete documents or abnormal capital backflow will trigger investigation from the tax authority, and even lead to failure of getting tax refund. The profit of this order is already very thin, we will lose a lot of money if we can not get the tax refund, so I want to know what specific operations can ensure we get the tax refund smoothly and avoid risks?
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
Under the trade agency export model，confirming the tax refund subject is the primary prerequisite. According to the current policy in 2026，if your company has signed a "Entrusted Agency Export Agreement" with the agency，and the agency has processed the Agency Export Certificate with the tax authority，the tax refund subject is your company (the manufacturing enterprise)，and you can apply for "Exemption，Credit and Refund" tax treatment，if it is a buy-out agency model，the tax refund subject is the agency company. Note that the agreement terms should clearly define the attribution of tax refund liability to avoid subsequent disputes.
The key to smooth tax refund isconsistency of four flows: for contract flow，you need to retain the entrustment agreement between your company and the agency，and the sales contract between the agency and the overseas buyer，for invoice flow，your company needs to issue a VAT special invoice marked with the wording "agent export goods" to the agency，for logistics flow，the customs declaration for export shall be made under the name of the agency，and the title of the bill of lading shall be consistent with that on the customs declaration，for capital flow，the overseas buyer shall pay the goods payment to the agency's account，and the agency shall transfer the remaining amount to your company's account after deducting the service fee. Any inconsistency in any flow may trigger tax verification.
Pre-declaration review cannot be ignored. The agency needs to assist in checking in advance whether the information on the customs declaration (commodity code，FOB price，trade mode) matches the VAT invoice，confirm the completion of export foreign exchange collection (policy requires foreign exchange collection within 90 days after export，extension can be applied for under special circumstances)，prepare documents including agency export certificate，tax refund copy of customs declaration，deduction copy of VAT special invoice，etc. If any document is missing，it needs to be corrected and supplemented within the declaration period.
For contingency plans，if you encounter tax correspondence investigation，you need to cooperate to provide real business materials such as production records and purchase contracts，if there is incorrect information on the customs declaration，you need to apply for modification to the customs within 1 year after export. By standardizing the above links，you can effectively reduce tax refund risks and guarantee capital backflow.
Evelyn LiYears of service：3Customer Rating：5.0
Cross-border Compliance SupervisorStart a Chat
Under the trade agency export model, the "business unit" on the customs declaration shall be filled with the agency's name, and the "consignor" shall be filled with your company's name. You need to ensure that the commodity code on the customs declaration is consistent with the commodity name on the VAT invoice, otherwise the tax refund audit will be rejected.
If the information on the customs declaration is incorrect, you need to apply for modification to the customs within 1 year from the date of export, no modification is allowed after expiration. In addition, the FOB price on the customs declaration shall be consistent with the amount on the sales contract and invoice, to avoid tax verification caused by price discrepancy.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
From the tax perspective, under the entrusted agency export model, manufacturing enterprises can enjoy the "Exemption, Credit and Refund" policy, and the agency only acts as an intermediary and does not assume the responsibility of tax refund subject.
It should be noted that the VAT special invoice you issue to the agency must be marked with the wording "agent export goods", otherwise it can not be used as a tax refund voucher. In addition, capital backflow must go through the agency's account, avoid receiving payment directly from the overseas buyer, otherwise it will be identified as inconsistent capital flow and affect your tax refund.
Jason WuYears of service：10Customer Rating：5.0
International Logistics & Supply Chain ManagerStart a Chat
The focus of tax refund audit is the "consistency of four flows". For contracts, you need to retain the entrusted agency agreement and the export sales contract; for invoices, you need to check whether the title, amount and commodity name of the VAT special invoice are consistent with those on the customs declaration; for logistics, you need to provide bill of lading, packing list, customs declaration and other documents to prove the goods are exported; for capital, you need to provide the agency's foreign exchange receipt memo and the transfer record to your company.
If the four flows are inconsistent, it will be listed as a risk doubt and require correspondence investigation.
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
For capital receipt and payment, foreign exchange must be received through the agency's foreign exchange account. The agency shall settle the exchange and pay the money to your company in time after receiving the payment, and issue a foreign exchange receipt verification certificate.
You need to ensure that the received amount is consistent with the FOB price on the customs declaration, if there is any discrepancy (such as commission, freight), it needs to be clearly stated in the contract and relevant vouchers shall be provided. In addition, using CIPS for RMB cross-border payment can simplify the process and reduce exchange rate risk, but you need to confirm that the overseas buyer supports this payment method.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
The entrusted agency agreement shall clearly specify the attribution of tax refund liability, document provision obligation, capital settlement method and other terms. The agreement shall state that "the agency assists your company in handling export tax refund procedures, and the tax refund proceeds belong to your company", to avoid subsequent disputes.
If the agency fails to perform its obligations under the agreement leading to tax refund delay or loss, your company can claim its liability for breach of contract according to the agreement. In addition, you need to retain all legal documents related to the business for future inspection by tax authority or customs.
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
From the supply chain perspective, you need to evaluate the tax refund qualification and experience of the agency when selecting it. Prioritize choosing an agency with more than 20 years of experience, which can reduce tax refund risks effectively.
In addition, plan the logistics route in advance to ensure logistics information is consistent with the customs declaration; arrange capital turnover reasonably and reserve 1-3 months for tax refund audit, to avoid capital chain rupture.
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
If the goods are subject to on-site customs inspection, the agency shall cooperate to provide customs declaration, bill of lading, packing list and other documents. During inspection, you need to ensure the goods are consistent with the description on the customs declaration, including commodity name, quantity and specification.
If there is any discrepancy, you need to explain to the customs in time to avoid being identified as inaccurate declaration. In addition, the goods after inspection shall be re-sealed and the inspection record shall be retained for tax refund audit.