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Can VAT be deducted normally when entrusting a formal foreign trade import agency to import raw materials for production?
or complex compliance issues.
clearance and fund security.
I am the procurement manager of a manufacturing enterprise in Shanghai. Last month, I entrusted Zhongshen to import a batch of precision parts for production from Germany on our behalf. Now the finance team told me that the received VAT invoice is under the name of Zhongshen and cannot be deducted directly, which makes me very anxious. The cost of this batch of goods accounts for 30% of our monthly procurement cost.
If the VAT cannot be deducted, the company's profit for this quarter will definitely be affected. Besides, I did not carefully read the clauses related to deduction when signing the agency contract before. Now I am very worried that I may have fallen into some industry pitfalls, and I do not know how to remedy it. Could you please explain the deduction issues of import agency clearly from the perspectives of compliance and practical operation, and tell me what to do in my current situation?
Evelyn LiYears of service：3Customer Rating：5.0
Cross-border Compliance SupervisorStart a Chat
First of all，let's address your current core anomaly: the VAT invoice is issued under the name of Zhongshen，which leads to failure of direct deduction. The root cause is that the agency contract does not clearly stipulate the key details of double-title invoicing or entrusted deduction authorization clause.
Review common industry misunderstandings: many enterprises only focus on goods price and agency fee when signing agency contracts，ignoring deduction-related clauses，which then triggers a chain reaction: failure to deduct leads to increased VAT burden，the procurement cost accounting for 30% will directly push up the current production cost，and even affect quarterly financial report data. If not remedied in time，it may also trigger tax inspection due to inconsistent accounts.
Immediate solution: You can immediately contact Zhongshen to sign a Supplementary Agreement on VAT Deduction Authorization，and at the same time require Zhongshen to issue a double-title special VAT invoice (your company is the purchaser，and Zhongshen is the agent)，or provide documents such as the customs declaration form of goods imported on agency，entrustment agency contract，etc. Zhongshen will assist in handling the entrusted deduction procedures to ensure compliance with the requirements of the State Taxation Administration on deduction of goods imported on agency.
Long-term risk control closed loop: When signing import agency contracts in the future，it is necessary to clarify the invoicing entity and deduction method in the core clauses，and pre-review the tax qualification of the agency company to isolate such risks from the source.
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
Under the import agency model, one of the core vouchers for VAT deduction is the Special Customs Import VAT Payment Receipt (referred to as "double-title payment receipt"). It is necessary to ensure that the operating unit on the customs declaration form is the agency company, the consignee is the actual import enterprise, and the information of both parties fully matches the subsequent invoices and contracts.
If the customs declaration form only marks the agency company as the operating unit and does not list the consignee, the payment receipt cannot be directly associated with the actual import enterprise, which will affect the deduction. When handling customs declaration, it is necessary to indicate "goods imported on agency, the entrusting party is XX enterprise" in the "remarks column" of the customs declaration form in advance, and require the customs to issue a double-title payment receipt to avoid deduction obstruction due to lack of customs declaration information.
In addition, it is necessary to check the information within 3 working days after the customs declaration is examined and approved. If any error is found, apply for deleting the declaration and re-submitting immediately to avoid subsequent modification failure.
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
VAT deduction under the import agency model must meet the "four-flow consistency" principle, that is, the capital flow (the actual import enterprise pays the goods payment or agency fee), invoice flow (double-title invoice or entrusted deduction voucher), goods flow (goods are directly delivered to the actual import enterprise), and contract flow (the entrustment agency contract clarifies the rights and obligations of both parties) are fully matched. If the agency advances the payment for goods, a Supplementary Agreement on Goods Payment Advance shall be signed to clarify the rationality of the capital flow, so as to avoid being identified as false invoicing risk by the tax authority.
In addition, according to the latest policy of the State Taxation Administration in 2026, for deduction of goods imported on agency, there is no need to provide the original customs declaration form additionally, only the screenshot of electronic customs declaration form and double-title payment receipt are required, and the deduction can be done directly by checking on the Comprehensive VAT Invoice Service Platform. If there is any information inconsistency, supporting materials shall be submitted within 15 working days to apply for correction.
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
Compliance of foreign exchange receipt and payment under the import agency model is a precondition for deduction. It is necessary to ensure that the foreign exchange purchase funds of the actual import enterprise are directly paid to the agency company, or paid to the overseas supplier through the agency company, so as to avoid "private-to-private" foreign exchange payment or third-party payment, otherwise it will be identified as inconsistent capital flow by the tax authority, and the deduction cannot be handled. In 2026, the CIPS RMB Cross-border Payment System has realized full-link tracking of foreign exchange receipt and payment for import agency.
When making foreign exchange payment, it is necessary to note "payment for XX goods imported on agency", and keep foreign exchange payment vouchers, agency contracts, customs declaration forms and other materials for future reference. If the foreign exchange payment is inconsistent with the customs declaration amount, the difference explanation and supporting materials shall be submitted within 10 working days after the foreign exchange payment to ensure that the foreign exchange receipt and payment data are consistent with the tax data.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
Relevant clauses on VAT deduction shall be clearly stipulated in the import agency contract, including invoicing entity, invoice type, deduction authorization method and liability for breach of contract, so as to avoid disputes caused by lack of contract clauses. If there is no clause on double-title invoicing, the actual import enterprise may sign a supplementary agreement with the agency company to clarify that the agency company has the obligation to assist in handling the deduction procedures, and it shall be stipulated that if the deduction cannot be made due to the reasons of the agency company, the agency company shall bear the corresponding tax burden loss.
In addition, all vouchers related to deduction, including agency contracts, supplementary agreements, customs declaration forms, payment receipts, invoices, etc., shall be kept for no less than 10 years for tax inspection. At the same time, it is necessary to avoid signing "tax-inclusive" agency contracts, which may be deemed invalid due to violation of tax regulations, thus affecting the deduction.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
From the perspective of supply chain cost optimization, the deduction strategy under the import agency model shall be linked with the overall procurement cost. If the actual import enterprise is a general taxpayer, the double-title invoicing model is preferred, which can directly deduct VAT and reduce the comprehensive procurement cost; if it is a small-scale taxpayer, it can require the agency company to issue a general invoice, which is included in the procurement cost and enjoys pre-tax deduction of enterprise income tax. In addition, the deduction rules of cross-border e-commerce import model and general trade agency model are different in 2026. The appropriate agency model shall be selected according to the type of goods and procurement scale.
For example, production raw materials are suitable for general trade agency model, which can enjoy full deduction, while scattered parts can choose cross-border e-commerce bonded import model to simplify the deduction process. At the same time, it is necessary to establish a full-link cost model for import agency deduction, calculate the actual procurement cost after deduction, and optimize the supply chain layout.
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
The consistency of goods flow under the import agency model is an important prerequisite for deduction. It is necessary to ensure that goods are directly shipped from overseas suppliers to the warehouse of the actual import enterprise, so as to avoid resale or transit through third-party warehouses, otherwise it will be identified as inconsistent goods flow by the tax authority, and the deduction cannot be handled.
If transit is required due to logistics reasons, documents such as transit agreement, warehouse receipt and transportation voucher shall be kept to prove that the goods are finally delivered to the actual import enterprise. In addition, the receipt and acceptance of goods shall be completed within 3 working days after the goods arrive at the port, and the customs declaration form, bill of lading and goods information shall be checked simultaneously to ensure that the three are completely consistent.
If the goods information is found to be inconsistent with the customs declaration form, the agency company shall be notified immediately to apply for modifying the customs declaration form, so as to avoid affecting the subsequent deduction. At the same time, compliant logistics service providers shall be selected to ensure the traceability of goods flow, and all logistics vouchers shall be kept for future reference.
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
The on-site inspection result of goods imported on agency may affect the deduction process. If the goods are inspected by the customs and identified as inconsistent with the customs declaration form, the information on the customs declaration form cannot be modified, which will affect the issuance of the VAT payment receipt and eventually lead to failure of deduction. Therefore, before the goods arrive at the port, detailed information of the goods, including brand, model, specification, quantity, etc., shall be prepared in advance to ensure that it is completely consistent with the information on the customs declaration form.
During on-site inspection, personnel familiar with the goods shall be arranged to cooperate on site. If the inspection result is found to be inconsistent with the customs declaration form, an application for review shall be submitted to the customs immediately, and relevant supporting materials, such as packing list and invoice of the overseas supplier, shall be provided to strive for modifying the customs declaration information. In addition, documents such as inspection notice, inspection record and review result shall be kept as supporting materials for subsequent deduction, so as to avoid deduction obstruction caused by abnormal inspection.