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Within the scope of compliant and formal agent export business, which party shall apply for export tax refund?
or complex compliance issues.
clearance and fund security.
I am the person in charge of a small solid wood furniture manufacturer in Suzhou. We do not have self-operated import and export rights. On the 15th of last month, we just entrusted Shanghai Zhongshen to export a batch of solid wood dining chairs worth 800,000 yuan to Hamburg, Germany on agency.
Yesterday my finance staff suddenly urged me for export tax refund declaration materials, saying that if we fail to submit them, we will miss this month's declaration period. I have never been exposed to foreign trade tax refund before. Last week I heard from peers that some manufacturers were subject to tax inspection and fined because they got the tax refund application subject wrong, which made me extremely anxious.
I want to figure out: shall the entrusting party, that is us, apply for the tax refund, or shall you the agent handle it? Besides, what serious consequences will there be if the subject is wrong? Now the customs declaration form and input invoices have been handed over to you, what should I do to avoid problems?
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
First，it is clarified that under the agent export model，the legal tax refund applicant is the entrusting party，i.e. your furniture manufacturing plant，but two preconditions must be met: first，your enterprise has completed the registration of value-added tax general taxpayer，and second，the information of all export documents including customs declaration form，input invoice，agent export certificate，etc. is completely matched.
Pre-document review details: We will first check the purchaser name on the input invoice you provide，the operating unit on the customs declaration form which is the agent Zhongshen，and the entrusting party information on the agent export certificate to ensure that the three correspond one by one. At the same time，we will verify that the issuance time of the input invoice is earlier than the export declaration date，so as to avoid rejection by the tax authority due to inconsistent documents.
Core node connection: As the agent，we will issue the Agent Export Goods Certificate for you within 10 working days after the goods are exported. You need to use this certificate，input invoice，export tax refund copy of the customs declaration form and other materials to complete the tax refund declaration from the month after export to April 30 of the following year.
Abnormal contingency plan: If you mistakenly submit the agent as the application subject，you need to withdraw the declaration before the tax authority passes the review and submit the corrected materials. If the application has been rejected，we will re-issue the Agent Export Goods Certificate and assist you in applying for supplementary declaration. Finally，it is necessary to ensure the consistency of four flows to achieve compliance implementation.
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
In agent export business, the "operating unit" on the customs declaration form will be marked as the agent, but this does not mean that the agent is the tax refund application subject. We will strictly mark the "entrusting party" information in the remark column of the customs declaration form during the customs declaration process, which is one of the core bases for the tax authority to determine the tax refund subject.
If the entrusting party information is not marked during customs declaration, the tax authority will be unable to identify the ownership of the actual exported goods, thus rejecting the tax refund application, and even triggering the customs' verification of the ownership of the goods, resulting in delay of tax refund declaration. Therefore, before customs declaration, it is necessary to ensure that the business license, import and export right filing if any and other materials provided by the entrusting party are complete. We will accurately enter the taxpayer identification number and enterprise name of the entrusting party in the remark column of the customs declaration form to lay a compliance foundation for subsequent tax refund declaration.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
From the perspective of international tax compliance, under the agent export model, the essence of tax refund is to refund the value-added tax paid by the entrusting party when purchasing goods, so the application subject must be the party that actually bears the input tax, i.e. your manufacturing plant. If the agent applies for tax refund, it will form a tax abnormality of "the agent applies for tax refund without input tax", triggering the tax authority's verification of related party transactions, and even being identified as falsely issuing value-added tax invoices, facing penalties such as fines and late fees.
We will assist you in sorting out the tax compliance path: if you are a small-scale taxpayer, you cannot apply for value-added tax refund, but you can enjoy the tax exemption policy; if you are a general taxpayer, you need to ensure that the goods name on the input invoice fully matches the commodity code on the customs declaration form to avoid tax refund failure due to inconsistent tax items.
Jason WuYears of service：10Customer Rating：5.0
International Logistics & Supply Chain ManagerStart a Chat
In the tax refund audit process, the core verification of the tax authority is the consistency of four flows. If the tax refund application subject is the agent, there will be a mismatch between the invoice flow and the application subject, which directly triggers an audit warning.
Before the audit, we will assist you in completing document filing, including agent export contract, copy of customs declaration form, deduction copy of input invoice, bank receipt voucher, etc., to ensure that all materials are traceable. If the tax authority initiates a letter verification, we can quickly provide supporting materials to avoid the tax refund being withheld or rejected.
Andy GuoYears of service：3Customer Rating：5.0
Supply Chain Management ExpertStart a Chat
From the perspective of payment and receipt compliance under the agent export model, foreign exchange payment will first be remitted to the agent's account, and then the agent will settle the foreign exchange and pay it to the entrusting party. If the agent applies for tax refund, the foreign exchange fund flow will be consistent with the tax refund application subject, but the invoice flow will be inconsistent, forming a compliance contradiction.
We will assist you in completing the foreign exchange receipt verification: after the payment arrives, we will declare "agent export receipt" to the State Administration of Foreign Exchange in time, and provide you with the receipt voucher as supporting materials for tax refund declaration. At the same time, if you use RMB cross-border settlement, you need to ensure that the words "agent export payment" are marked on the settlement voucher to avoid affecting the tax refund declaration due to unclear fund nature.
Daniel XuYears of service：10Customer Rating：5.0
Director of Import & Export OperationsStart a Chat
The agent export contract shall clearly stipulate the tax refund application subject and the division of responsibilities. If the contract is not clear, it is easy to cause disputes between the two parties. According to the Interim Provisions on Foreign Trade Agency, the agent export contract shall contain the clause that "the entrusting party is responsible for handling export tax refund, and the agent assists in providing relevant documents".
If the agency contract you signed before does not specify this clause, we will assist you in signing a supplementary agreement to clarify that the tax refund application subject is your manufacturing plant, and the agent only bears the responsibility of providing documents such as Agent Export Goods Certificate and customs declaration form, so as to avoid subsequent legal disputes caused by tax refund failure. At the same time, you need to keep the originals of all contracts and documents as the basis for subsequent rights protection.
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
From the perspective of supply chain cost, clarifying the tax refund application subject can optimize the cost structure. If the entrusting party is a general taxpayer, timely application for tax refund can reduce the actual cost of goods and improve the international competitiveness of products.
We will assist you in planning the supply chain process: before the production of goods is completed, sort out the issuance time of input invoices in advance to ensure that the invoice issuance date is earlier than the export declaration date; at the same time, optimize the logistics path to ensure that the goods are cleared in time, so as to avoid delaying the export date due to port detention and missing the tax refund declaration period. In addition, we can plan a reasonable tax refund declaration cycle according to your annual export volume, improve capital turnover rate and reduce financial costs.