Can domestic enterprises apply for export tax refund when entrusting Japanese agents to export relevant goods?
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I am a salesperson of a foreign trade company in Shanghai, mainly engaged in cross-border agency business of Chinese mechanical and electrical products. Last month, I just received an entrustment from a Japanese customer to help them export a batch of industrial sensors from Shanghai Port to Tokyo.
I was only familiar with the tax refund process for self-operated exports before, and now for agent exports, I wonder if we can apply for export tax refund? Besides, the customer is from Japan, and the foreign exchange receipt is transferred from a Japanese account, will it affect the tax refund?
In addition, how to fill in the title of documents for agent export such as bill of lading and customs declaration form? I am afraid that mistakes will lead to the rejection of tax refund and even affect subsequent business cooperation. Can you answer these questions for me in detail?
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
First of all，it is clear that in 2026，domestic enterprises entrusted by Japanese customers to export eligible Chinese goods can normally apply for export tax refund，but they need to meet three core prerequisites: the goods are within the scope of VAT collection，have actually departed from the country and completed customs formalities，the foreign exchange receipt is compliant，and the information of all documents is fully matched.
Pre-document review details: The "operating unit" column of the customs declaration form for agent export must be filled with the entrusted party (i.e. your company)，and the "consignor" column can be filled with the entrusting party or the entrusted party according to the actual situation. At the same time，a full set of documents such as the formal agent export agreement signed by both parties，the special VAT invoice issued by the entrusting party，ocean bill of lading，packing list and dock receipt shall be kept. The name，quantity and amount of goods on all documents shall be fully consistent with the electronic data of the customs declaration form to avoid inconsistency between documents and goods.
Core node connection: Within 15 days after the goods actually depart from the country and the electronic information of the export goods customs declaration form is obtained，the *Certificate of Agent Export Goods* shall be issued online through the China International Trade Single Window，which is the core voucher for the entrusting party to declare tax refund. In 2026，the tax authority optimized the electronic data transmission process of the agent export certificate，which can be directly synchronized to the tax refund review system without submitting paper materials offline，greatly shortening the handling time.
Abnormal contingency plan: In case of delay in foreign exchange receipt，inconsistency of document information，abnormal customs inspection and other situations，you can apply to the competent tax authority for deferred declaration of tax refund within the VAT declaration period in April of the following year，and you need to submit a written explanation and relevant supporting materials. If you are included in the scope of letter investigation by the tax authority，you shall cooperate to provide materials such as agency agreement，logistics track voucher，foreign exchange receipt slip，inspection record，etc。to ensure that the goods flow，capital flow，document flow and invoice flow are completely consistent.
Key points for compliance implementation: It should be noted that the foreign exchange receipt from Japanese customers must be remitted through their compliant corporate accounts，and it is strictly prohibited to receive foreign exchange through personal accounts or third-party non-related accounts. At the same time，complete transaction records of the agency business，including communication records between the two parties，payment vouchers，etc。shall be kept to avoid being identified as false agency business. In addition，if the entrusting party is a Japanese enterprise that cannot provide a special VAT invoice，it is necessary to confirm whether the goods are within the scope of goods deemed to be self-produced，or adjust the trade mode to self-operated export by the entrusted party to meet the tax refund conditions.
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
The "operating unit" column of the customs declaration form for agent export must be filled with the entrusted party, which is one of the core requirements for tax refund review. If the information of the entrusting party is filled in by mistake in the early stage, you shall apply to the customs for deleting the declaration and re-declaring in time to avoid the subsequent tax refund failing to pass the review.
In 2026, Shanghai Port has realized the electronic pre-review function for agent export customs declaration forms, which can verify whether the document information matches in advance and reduce the subsequent cost of modifying the declaration. In case of questioning by customs on price verification, you shall provide agency agreement, goods purchase contract, cost accounting materials, etc. to prove the rationality of the transaction price and avoid the dutiable value being adjusted.
In addition, the customs code classification of agent export goods must be accurate. Different codes correspond to different tax refund rates. Wrong classification may lead to inconsistent tax refund amount or suspended tax refund.
It is recommended to entrust a professional institution to conduct pre-classification before customs declaration to ensure that the code is consistent with the actual attributes of the goods. At the same time, it should be noted that some commodities exported to Japan may involve Japanese import control, and it is necessary to confirm in advance whether relevant permits are required to avoid the goods being detained at the port of destination.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
The logistics route for agent export to Japan shall be selected in combination with the time limit and cost of goods. The voyage of direct routes is about 1-2 days, and the transit route has lower cost but longer time, which shall be determined according to customer needs.
The "consignee" column of the bill of lading shall be filled with the Japanese customer or its designated consignee, and the endorsement method shall comply with the provisions of the trade contract, usually blank endorsement or straight endorsement, to ensure the compliance of cargo right transfer.
Attention shall be paid to the setting of free storage period and free detention period. The conventional free storage period of Shanghai Port is 7 days, and the free detention period is 14 days. If the time limit is exceeded, detention fee and port storage fee will be incurred.
You can negotiate with the shipping company to extend the free storage period to avoid extra costs. At the same time, you shall track the logistics track of the goods, and timely transmit the bill of lading information to the entrusting party to ensure that they can complete the customs clearance procedures in Japan in time. In case of overbooking or container rolling by the shipping company, you shall adjust the shipping space in advance and select a standby shipping company to avoid delaying the delivery time and affecting the tax refund declaration.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
The tax structure of agent export business shall ensure the authenticity and compliance of transactions to avoid being identified as related party transactions for profit transfer.
If there is a related relationship between the entrusted party and the entrusting party, it is necessary to prepare related party transaction pricing materials to prove that the transaction price conforms to the arm's length principle and avoid being adjusted by the tax authority. In 2026, China's tax authorities strengthened the supervision of cross-border related party transactions, so it is necessary to complete the filing work in advance.
For the import VAT of Japanese customers, you can choose the VAT deferral policy, that is, you do not need to pay VAT when importing in Japan, and declare and pay it after the goods are sold, which can ease the capital pressure of enterprises.
However, attention shall be paid to the compliance requirements of VAT deferral, and authentic trade vouchers and storage certificates shall be provided. In addition, if the entrusting party sells the goods to a third party, it is necessary to confirm whether it meets the export tax refund conditions of China to avoid the risk of falsely issuing special VAT invoices.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
The foreign exchange receipt for agent export to Japan shall go through compliant cross-border payment channels, and SWIFT or CIPS system can be selected to ensure that the capital flow is consistent with the goods flow and document flow. In 2026, China's foreign exchange administration authority optimized the process of cross-border RMB settlement, so RMB can be used for foreign exchange receipt to avoid risks caused by exchange rate fluctuations.
It should be noted that the subject of foreign exchange receipt must be consistent with the operating unit on the customs declaration form. If the entrusting party designates a third party to receive foreign exchange, a tripartite entrustment agreement for foreign exchange receipt shall be signed and filed with the foreign exchange administration authority.
If there is a difference between the foreign exchange receipt amount and the customs declaration amount, reasonable supporting materials, such as commission deduction agreement, freight advance voucher, etc., shall be provided to ensure the authenticity of the difference. At the same time, you shall settle the foreign exchange and balance the account in time after receiving the foreign exchange, to avoid the account hanging affecting the tax refund declaration.
In 2026, the foreign exchange administration authority launched an electronic verification system for cross-border foreign exchange receipt and payment, which can automatically compare the foreign exchange receipt information and customs declaration information, reducing the time of manual review.
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
The agent export contract shall clarify the rights and obligations of both parties, including clauses such as tax refund responsibility, document delivery, foreign exchange receipt risk, and liability for breach of contract.
It is recommended to add a force majeure clause as a fallback, to clarify the handling method in case of force majeure events such as customs inspection and logistics delay. If settlement by letter of credit is adopted, the soft clauses of the letter of credit shall be carefully reviewed to avoid the situation of being unable to negotiate.
If the goods involve intellectual property rights, it is necessary to confirm whether the entrusting party has a legal intellectual property right certificate to avoid being detained by the customs during export. At the same time, a Letter of Intent (LOI) shall be signed to clarify the intellectual property right responsibility of the entrusting party for the goods.
In case of intellectual property right disputes, the entrusting party shall bear all responsibilities. In addition, attention shall be paid to Japan's import intellectual property protection regulations, and it is necessary to confirm in advance whether the goods infringe local intellectual property rights to avoid the goods being confiscated at the port of destination.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
Agent export goods may be randomly inspected by the customs, so preparations shall be made in advance. First, confirm the content of the customs inspection notice, and clarify the scope and requirements of the goods to be inspected.
If the goods need to be unpacked for inspection, a professional loading and unloading team shall be arranged to ensure that the packaging of the goods is intact and the seal number is consistent with that on the customs declaration form.
If the customs requires the goods to be sent for inspection, you shall timely provide the quality certification documents, test reports and other materials of the goods, and cooperate with the customs to complete the testing process. In 2026, the inspection efficiency of Shanghai Port has been improved, with the average inspection time not exceeding 24 hours.
However, if there are doubts about the goods, the inspection time may be extended. Attention shall be paid to the protection of seals during inspection.
If the seal is damaged, you shall report to the customs in time and replace the seal to avoid affecting the cargo right certificate of the goods. At the same time, photos and records of the inspection site shall be kept as auxiliary materials for subsequent tax refund declaration.
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
For the document filing of agent export tax refund, a full set of materials shall be kept, including agent export agreement, customs declaration form, bill of lading, foreign exchange receipt slip, special VAT invoice, etc. The filing materials shall be kept for at least 10 years for the verification of the tax authority. In 2026, the tax authority launched an electronic system for document filing, which allows uploading filing materials to the Single Window without keeping paper materials offline, facilitating subsequent management.
If you are subject to letter investigation by the tax authority, you shall provide complete materials within 15 days, including transaction records of the agency business, logistics vouchers, foreign exchange receipt certificates, etc., to ensure the consistency of the four flows. If the materials are incomplete or there are doubts, the tax refund may be suspended or rejected.
It is recommended to conduct pre-declaration verification before tax refund declaration, and verify whether the document information matches through the pre-declaration system of the Single Window, so as to find and solve problems in advance. In addition, attention shall be paid to the time node of tax refund declaration, which shall be completed within the VAT declaration period in April of the following year after the goods depart from the country, and no tax refund can be applied for after the deadline.