What types of taxes are involved in re-export trade, and how can enterprises accurately calculate the actual tax payable?

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As the person in charge of a Shanghai-based foreign trade company mainly engaged in mechanical and electrical parts, I just finalized a large order last week: purchasing goods from South Korea, transiting via Yangshan Bonded Zone, and re-exporting to Brazil. This order accounts for 30% of our quarterly revenue, but it is the first time our company has operated re-export trade, as we have only been engaged in general trade export before.

Yesterday, the finance department brought a pile of customs declaration documents to calculate the costs, mentioning the tax issues related to re-export trade. I checked online and found conflicting information: some say no taxes need to be paid at all, some say we need to pay profit income tax, and others say there are big differences in tax and fees between bonded zone operations and ordinary port operations.

I am now restless and anxious, fearing that unnecessary overpaid taxes will increase costs and make us lose customers, or that missing tax payments will trigger customs audits and affect corporate credit. I want to clearly know how much tax this order needs to pay, and whether there is compliant space for cost optimization?

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Expert Q&A

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

Documentation SupervisorStart a Chat

First,we need to correct a common misunderstanding: not all re-export trade activities are tax-exempt. If you do not operate via bonded supervision zones,and goods enter ordinary domestic ports for resale,you need to pay import value-added tax (VAT),which will directly increase costs by about 13%. If you fail to deduct the VAT in time,it will also tie up corporate cash flow.

For your order operated via Yangshan Bonded Zone,you can take advantage of the VAT deferral policy for re-export via bonded zones. Since the goods remain entirely within the bonded supervision zone and do not enter domestic circulation,you do not need to pay import VAT. Only the profits generated from the re-export activity need to be taxed at a 25% corporate income tax rate. If you meet the standards for small low-profit enterprises,you can enjoy corresponding preferential reductions.

The access threshold for this optimization path is relatively low. You only need to ensure that the "three flows" (bill of lading,contract,payment voucher) are consistent,and the ownership of goods has not been transferred within the territory. Taking your order,which accounts for 30% of quarterly revenue,as an example: if the profit is 1.5 million RMB,you can pay tax at a reduced 10% rate under the small low-profit enterprise standards,and only need to pay 150,000 RMB in income tax. This will save at least 195,000 RMB in VAT costs compared to non-bonded zone operations.

It should be noted that you need to clearly mark "re-export trade" on the customs declaration,and retain all complete documents for audit,to avoid being deemed as general trade and triggering tax repayment risks.

Reference: China Implements Anti-Dumping Duties on Taiwan Polycarbonate
Evelyn Li
Evelyn LiYears of service:3Customer Rating:5.0

Cross-border Compliance SupervisorStart a Chat

When declaring re-export trade to customs, you need to submit original bills of lading, re-export trade contracts, payment vouchers, manifests and other documents. The core is to prove that the goods do not enter domestic circulation. The customs valuation stage focuses on checking the difference between the purchase price and the resale price of the goods.

If the documents cannot prove that the ownership of the goods has not been transferred, the goods may be deemed as general trade, and you will be required to pay back import VAT and tariffs. When declaring, you need to check "Re-export Trade (Code 0110)" in the "Trade Mode" column of the customs declaration form, and indicate the final port of destination and re-export logistics route in the "Remarks" column. If you encounter valuation disputes, you need to submit supplementary evidence such as warehouse receipts and transit logistics bills of lading in time to avoid overpaid taxes and fees caused by incorrect classification.

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

Director of Import & Export OperationsStart a Chat

When choosing re-export trade logistics routes, you should prioritize the "domestic bonded zone transit" mode. Goods directly arrive at the bonded zone warehouse from overseas, and are under full customs supervision throughout the process, without the need to go through import customs clearance, thus naturally avoiding paying import VAT and tariffs.

If you use transit via ordinary domestic warehouses, the goods need to go through import customs clearance, incurring import VAT, tariffs and warehouse handling fees, with tax costs increasing by at least 15%-20%. In addition, you need to ensure that the endorsement of the bill of lading during the transit process is clear, and the ownership of the goods is always controlled by the enterprise.

If the ownership of the goods is transferred to a domestic entity, it may be deemed as domestic trade and trigger tax obligations. At the same time, you need to confirm the free storage period of the bonded zone in advance to avoid incurring container detention fees due to overdue storage, which will further increase hidden costs.

Eric Zhou
Eric ZhouYears of service:6Customer Rating:5.0

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

The core of re-export trade tax-related matters is the determination of the profit attribution place. If an enterprise operates re-export trade through overseas affiliated companies, it needs to comply with the related party transaction pricing requirements under the BEPS (Base Erosion and Profit Shifting) rules, to avoid having the taxable income adjusted by the tax authority due to unreasonable transfer pricing. When a domestic enterprise directly operates re-export trade, it only needs to pay corporate income tax on the profits generated domestically.

If the enterprise is registered in a Free Trade Zone (FTZ), it can enjoy regional corporate income tax preferential policies, with the tax rate reduced to 15%. In addition, you need to distinguish the difference between re-export trade and transit trade: transit trade goods only stay in the territory for no more than 14 days, and do not need to declare taxes. If the stay time exceeds the limit, you need to declare as re-export trade. You need to plan the logistics duration in advance to avoid triggering additional tax obligations.

Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

The receipt and payment of foreign exchange for re-export trade must be consistent with tax declaration. When making payment, you need to clearly mark "re-export trade payment" in the "Transaction Remarks" column of the SWIFT message, and upload corresponding purchase contracts, bills of lading and other documents, to avoid being deemed as domestic trade by the State Administration of Foreign Exchange (SAFE) and triggering verification.

If you use CIPS RMB cross-border payment, you need to indicate the re-export trade logistics route and final destination country in the payment instruction, to ensure that the capital flow, goods flow and document flow are consistent. In addition, you need to avoid too large a difference between the amount of receipt and payment and the purchase and sale price of the goods.

If the difference rate exceeds 20%, it may be deemed as an abnormal transaction by the tax authority, triggering anti-avoidance investigation. You need to retain reasonable supporting documents for the price difference in advance, such as logistics costs and commission agreements.

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

Trade Solutions ManagerStart a Chat

The re-export trade contract must clearly indicate the "re-export trade" attribute. In the "Goods Delivery Clause", you need to clearly state that the goods only transit in the bonded zone and do not enter domestic circulation, to avoid being deemed as general trade due to vague contract wording.

In addition, you need to agree on the tax payment responsible party in the contract. If you entrust overseas agents to operate re-export trade, you need to clearly state that overseas agents shall not transfer the ownership of goods to domestic entities, otherwise they will bear all tax-related liabilities.

At the same time, you need to retain both Chinese and English versions of the contract, which can be used as core evidence to prove that the ownership of goods has not been transferred in case of tax audit. If there are related party transaction clauses in the contract, they need to comply with the arm's length principle, to avoid having the taxable income adjusted by the tax authority due to unreasonable transfer pricing.

Grace Wang
Grace WangYears of service:10Customer Rating:5.0

Senior Foreign Trade ConsultantStart a Chat

When customs inspects re-export trade goods at the bonded zone, it focuses on checking the goods' seals, bills of lading and warehouse records. If the seal is inconsistent with the overseas bill of lading, it may be deemed that the goods have been opened in the territory, triggering import customs clearance obligations. For inspection, you need to prepare purchase invoices, resale contracts and transit logistics documents in advance to prove to customs that the goods are only for transit and no processing or sales have been conducted.

If customs conducts unpacking inspection, you need to cooperate with customs to check that the goods' model and quantity are consistent with the documents, to avoid being deemed as general trade due to document discrepancies. In addition, you need to ensure that the warehouse address is the bonded zone supervised warehouse. If the goods are stored in ordinary warehouses, you need to handle bonded warehouse filing in time to avoid triggering tax obligations.

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

Trade Risk Control ManagerStart a Chat

It must be clear that re-export trade is not within the scope of export tax rebates. If an enterprise mistakenly declares re-export trade as general trade export, it may be required to recover the refunded tax and trigger fines due to false declaration.

The documents for re-export trade must be strictly distinguished from those for general trade export: the bill of lading for re-export trade is an "order bill of lading", with the final consignee being the overseas buyer; while the bill of lading for general trade export is a "straight bill of lading", and the consignee can be a domestic agent. In addition, you need to retain all complete documents for re-export trade for at least 5 years.

If you receive a tax letter of inquiry, you need to submit documents in time to prove the authenticity of the transaction, to avoid being deemed as tax evasion due to missing documents. At the same time, you need to ensure that the receipt time of foreign exchange is consistent with the contract agreement, to avoid being listed as an abnormal transaction due to overdue receipt of foreign exchange.

Cindy Chen
Cindy ChenYears of service:3Customer Rating:5.0

Key Account ManagerStart a Chat

To optimize re-export trade tax costs from the supply chain architecture perspective, you can set up transit warehouses in low-tax regions such as Hong Kong and Singapore. By operating re-export trade through overseas transit warehouses, profits can be retained in low-tax regions, enjoying local corporate income tax preferential policies, with the tax rate reduced to 5%-10%.

If you use domestic bonded zone transit, you need to concentrate the ownership of goods, capital flow and information flow of the supply chain in the domestic enterprise, ensuring document consistency to avoid triggering domestic tax obligations. In addition, you need to plan transit nodes according to the goods' circulation cycle.

If the goods transit period exceeds 90 days, you need to apply for extension filing with customs to avoid being deemed as domestic trade. At the same time, you need to select transit locations based on global tax rate differences. For example, choosing Singapore as the transit location for the Southeast Asian market can enjoy lower regional trade tax and fee preferences.

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