Complete Guide and Key Considerations for Filling RMB FOB Price in Export Tax Refund Declaration

Export Tax Refund Declaration: Policy Core and Fundamental Logic of RMB FOB Price Declaration

The declaration data for export tax refund is interlinked,and the "FOB Price" on the customs declaration is the cornerstone for calculating the tax refund amount.Since the Customs General Administration further deepened tax collection and management reforms in 2025,data linkage between tax and customs systems has become closer,imposing almost stringent requirements on data consistency and rationality.The declaration of RMB FOB Price is no longer a simple numerical conversion but a systematic project involving trade term understanding,exchange rate application,and document matching.A single declaration error can result in document inconsistency being automatically flagged by the system,or even trigger tax inspection,delaying the tax refund process for the entire batch.

The current policy environment emphasizes "data-driven supervision." Tax authorities use big data models to compare historical export prices,industry average prices,and major market fluctuations,automatically alerting to abnormal quotations.This means that the RMB FOB Price declared by enterprises must not only be internally logically consistent but also withstand horizontal and vertical data comparisons.

Key Point 1: Clear Declaration Standards and Conversion Basis

Policy clearly stipulates that the FOB Price on export invoices (or proforma invoices) shall be used as the basis for tax refund declaration.A common operational misunderstanding is that many enterprises directly use the USD-denominated FOB amount on the customs declaration and multiply it by an estimated exchange rate for declaration.The correct approach is to convert the foreign currency price to RMB based on the customs declaration electronic information and strictly apply the midpoint exchange rate published by the People’s Bank of China on the export declaration date or the first working day of the month.

The key parameter is the selection of exchange rate.According to the Announcement of the State Administration of Taxation on the Management Measures for Value-Added Tax and Consumption Tax on Export Goods and Services and related interpretations,once an enterprise selects the exchange rate for the export month (the first day of the month or the transaction date),it shall not change it within a natural year.This selection must be clearly defined and maintained consistently at the first declaration,as arbitrary changes will become a focus of subsequent inspections.

Key Point 2: Price Rationality Verification Becomes a Focus

With the deepening of the "delegation of power,management optimization,and service enhancement" reform,pre-approval procedures have been reduced,but .In 2026,the audit focus increasingly centers on the commercial rationality of declared prices.Particularly in the following cases,the system will pay more attention:

• Abnormal fluctuations in export prices for the same product within a short period without reasonable commercial explanation;
• Export prices significantly lower than the average level of similar products in the same industry over a long period;
• Transaction pricing with related companies that does not comply with the arm’s length principle.

Tax authorities will retrieve export data for similar products from the same period or recent periods as a reference.If an enterprise cannot provide evidence such as contract terms or market analysis reports supporting its special pricing,the relevant tax refund application may be suspended and referred to manual review.

Accurate RMB FOB Price Declaration: Opportunities,Challenges,and Responses for Enterprises

Accurate declaration of RMB FOB Price directly and profoundly impacts enterprise cash flow and operational safety.Understanding its dual impacts is the premise for effective tax management.

From an opportunity perspective,accurate declaration is the "passport" for enterprises to enjoy efficient tax refund services.Once data passes the inspection,tax refund funds can be returned to the enterprise account within the normal cycle (currently generally 1-2 weeks after process optimization),effectively alleviating capital pressure and improving turnover efficiency.In a competitive foreign trade environment,rapid capital recovery is itself a competitive advantage.Additionally,maintaining high-accuracy declaration records over the long term helps enterprises accumulate good credit qualifications in customs and tax systems,potentially enjoying more convenient customs clearance and tax refund measures in the future.

However,challenges are equally severe.The greatest challenge stems from rising compliance costs.Enterprises need to establish or improve a collaborative mechanism covering business,finance,and customs,ensuring consistent FOB price expressions and accurate amount conversions across contract signing,invoice issuance,customs declaration,and tax refund application.This poses a high management barrier for many small and medium-sized foreign trade enterprises,particularly factories or traders without professional teams.Another hidden challenge is lagging policy understanding.Tax and customs regulatory documents are frequently updated,and minor adjustments to declaration systems may change operations.If enterprises fail to keep up,they may easily use outdated habits leading to errors.

Zhongshen’s Agency Services: Transforming Professional Competence into Practical Benefits for Clients

Facing the complexity and high risk of RMB FOB price declaration,the value of professional foreign trade agencies lies in transforming policy provisions into executable,monitorable,and traceable operational processes.With over 20 years of practical experience,Zhongshen has built a full-link risk control and service solution from data source to tax refund receipt for enterprises.

Service Implement 1: Pre-emptive Price Review and Document Calibration

Our service does not begin after customs declaration but is embedded in the customer order confirmation stage.Manager Zheng’s team will review contracts and invoices provided by clients before preparing customs declaration documents.They focus on verifying whether the trade term is FOB,ensuring accurate amount calculations,and conducting simulated conversions based on the latest exchange rate policies to identify potential issues such as unclear price terms or currency confusion in advance.This "pre-intervention" model fundamentally avoids subsequent chain reactions caused by basic document errors,ensuring the FOB price on the customs declaration is accurate and tax-refundable from the start.

Service Implement 2: Systematic Declaration and Discrepancy Handling Mechanism

We use our proprietary information system to embed exchange rate application rules into the process.The system automatically retrieves official exchange rates,converts according to the enterprise’s selected method (first day of the month or transaction date),and generates RMB FOB price data required for customs declaration and tax refund application,ensuring data consistency and logical coherence throughout the process.When minor discrepancies arise between customs statistics prices and declared prices due to rounding,our document specialists will issue an explanation with calculation details as an attachment to the tax refund application,effectively resolving rejection issues due to minor discrepancies.

Service Implement 3: Professional Support for Price Rationality Inquiries

When an enterprise’s export products are priced below market norms due to special materials,customized processes,niche markets,or clearance promotions,Zhongshen provides critical support.We assist enterprises in organizing complete evidence chains,including customized contract terms,cost structure analysis,and market pricing reports,and issue explanatory statements as a professional entity.Our senior consultants understand the inspection focus areas and can communicate effectively using industry terminology,transforming enterprise business practices into tax authority-recognized logical evidence to protect legitimate tax refund rights.

Action Recommendations for Foreign Trade Enterprises

Regardless of whether an agency is commissioned,enterprises should establish an internal control awareness for RMB FOB price.An immediate actionable recommendation is: designate a person (or department) to confirm and record the fixed conversion exchange rate at the beginning of each month and notify relevant business,finance,and customs personnel.All export contracts,invoices,and internal settlement documents under FOB terms must use this unified exchange rate for preliminary calculation and annotation when denominated in RMB.This simple action establishes a unified price data foundation internally,significantly reducing subsequent issues caused by exchange rate confusion and laying a solid foundation for smooth collaboration with agencies.