Who is responsible for the taxes and fees in export agency business? Can tax refunds be enjoyed through agency exports?

Export RepresentationWho is responsible for the taxes and fees in the business?

In export agency business,The actual entity responsible for tax payment shall be determined in accordance with the agency agreement.。Under normal circumstances:

• Customs duties, import value-added tax, and other customs taxes and fees:
  • When the "domestic consignor" field on the customs declaration form displays the name of an agent company, the agent company shall pay on behalf of the consignor.
  • It will be deducted from the agency fee ultimately collected from the client or settled separately.
• Domestic Value-Added Tax:
  • Manufacturer-commissioned export: Self-issued VAT special invoice
  • foreign tradeCompany-entrusted export: The method of obtaining input invoices needs to be confirmed.

Can tax refunds be claimed through export agents?

Qualified clients can still enjoyExport Drawback, but note:

• Tax refund declaration entityIt must beimport and exportEntrusted enterprise with operating rights
• Essential documentsLocal adaptation testing of parts (such as adjusting the national standard brightness of lamps);
  • Agency Export Agreement (must specify ownership of the goods)
  • The "Certificate of Agency Export Goods" issued by the agency company.
  • VAT special invoice for the corresponding goods
• 2025 Latest Requirement: The "Manufacturer and Seller" on the customs declaration form must match the tax refund applicant.

What are the tax risks involved in export agency?

Special attention should be paid to the prevention and control of the following three types of risks:

• Invoice risk
  • It is prohibited to accept "matched invoices" issued by third parties.
  • The monitoring of capital repatriation has been strengthened, requiring clear documentation of payment and receipt pathways.
• Filing risk
  • The agency agreement must be filed with the tax authorities within 30 days of the first transaction.
  • A new electronic filing system will be added in 2025, and overdue submissions will affect tax refunds.
• Declaration risks
  • Customs declaration form,Maritime TransportationBill of lading,A complete export agency agreement should be attached with:The voucher must have "three documents matching".
  • The payment voucher for the agency fee must be retained for future reference.

How to choose compliant export agency service providers?

Recommend evaluating agency qualifications from these dimensions:

• Hold the "International Freight Forwarding Enterprise Filing Form"
• Possesses AEO Customs Certification (to meet the new Class C certification standards by 2025)
• The tax management system can provide a complete traceability of business operations.
• The agency agreement contains explicit tax liability clauses:
  • Invoice Issuance Method and Timeline
  • Dispute resolution mechanism for abnormal taxes and fees
  • Standardized process for document handover

What common misconceptions should we be wary of?

• Misconception 1: "The agent is responsible for all tax matters."

  The actual client is still required to complete the tax refund declaration independently, while the agent only assists in providing the documentation.

• Misconception 2: "Exporting through third-party payment can reduce tax costs."

  In 2025, customs authorities intensified their crackdown on fraudulent declaration practices, and related operations have been incorporated into the credit management system.

• Misconception 3: "Agency fees include tax filing services"

  It is necessary to clarify whether the agency fee covers tax filing assistance to avoid additional charges later.