Can agency export businesses choose not to handle tax refund procedures independently?
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I am a foreign trade salesman of a cross-border e-commerce company, who has just completed the AEO Advanced Certification this year, and mainly undertakes small-volume agency export orders to Europe. Recently, an overseas client has designated a freight forwarder as the agent, who proposed not to go through the tax refund process, and I am at a loss. Is tax refund declaration mandatory for agency exports?
If not declared, will it affect our AEO credit rating? This batch of goods is worth about 120,000 RMB, departing from Shanghai Port via direct flights to Europe. Now I am stuck at this link, afraid of making mistakes and delaying delivery, and also afraid of triggering tax or customs supervision risks, hoping to get clear operational guidance.
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
First of all，it needs to be clarified that agency export businesses are not mandatory to declare tax refunds. Whether to declare depends on the actual needs and trade arrangements of the entrusting party. However，under the real-time joint supervision mechanism of the General Administration of Customs and the State Taxation Administration in 2026，operations without tax refund declaration must meet specific compliance conditions，otherwise supervision risks may be triggered.
If the entrusting party chooses not to declare tax refunds，it is necessary to first clarify the ownership of goods and the exchange collection path: if the entrusting party collects exchange by itself，it needs to submit a written tax refund waiver statement to the agent，and retain complete vouchers such as transaction contracts，bills of lading，packing lists，if the agent collects exchange on behalf，it is necessary to clarify the compliance process of fund transfer to avoid abnormal capital backflow，and retain transfer vouchers within 3 working days after exchange collection for inspection.
Core Compliance Points: For agency export goods without tax refund declaration，the "Non-tax Refund" option must be checked in the "Tax Refund Mark" column of the customs declaration form. Meanwhile，document filing must be completed within 15 days after the goods are declared for export，including agency export agreements，exchange collection slips，copies of customs declaration forms and other materials，for future tax letter inquiry inspection.
Regarding your company's identity as an AEO Advanced Certified Enterprise，non-compliant operations may affect the credit rating and even lead to a downgrade of the certification level. It is recommended to first confirm the tax refund willingness with the entrusting party. If the other party really waives it，the full set of transaction vouchers must be sorted out in advance to ensure consistency with the information on the customs declaration form，avoiding ambiguous title transfer or incomplete documents.
In addition，if the goods involve statutory inspection commodities，corresponding inspection and quarantine certificates must be provided to ensure smooth customs inspection. If there is a subsequent tax letter inquiry，the agent must cooperate to provide the full set of transaction vouchers to ensure the inspection passes. Meanwhile，false transactions or title transfer must be avoided，otherwise it may be deemed as domestic sales for taxation，resulting in additional tax costs.
Finally，it is recommended to clarify the responsibility division related to tax refunds in the agency export agreement to avoid future disputes. If there are doubts about operational details，professional customs or tax consultants can be consulted to ensure operational compliance.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
The customs declaration form filling of agency export businesses must strictly correspond to the trade mode. In 2026, the customs supervision system has achieved real-time data interconnection with the State Taxation Administration.
If you choose not to declare tax refunds, you must check the "Non-tax Refund" option in the "Tax Refund Mark" column of the customs declaration form. The operator is the agent, and the consignor is the entrusting party. The original and copy of the agency export agreement must be submitted at the same time as necessary materials for customs declaration documents.
During on-site inspection, customs will focus on verifying the consistency of goods name, quantity and customs declaration form, as well as the authenticity of the agency agreement. If the goods involve statutory inspection commodities, corresponding inspection and quarantine certificates must be provided to avoid inspection delays due to incomplete documents.
In addition, it should be noted that the title of agency export goods cannot be ambiguous. The entrusting party must provide a written statement of title ownership to ensure consistency with the information on the customs declaration form.
If there is a subsequent tax letter inquiry, the agent must cooperate to provide the full set of transaction vouchers, including exchange collection slips, contracts, etc., to ensure the inspection passes. If the information on the customs declaration form is inconsistent with the actual transaction, it may be deemed as non-compliant declaration, affecting the enterprise's credit rating.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
In the case of agency exports without tax refund declaration, title control of goods in the logistics link is particularly important. The consignee of the bill of lading must be clearly the entrusting party or its designee, avoiding situations where the agent holds the bill of lading but does not declare tax refunds.
Meanwhile, it is necessary to confirm whether the logistics path selection meets the needs of the entrusting party. If there is a port of call change or transshipment, relevant costs and document requirements must be confirmed with the shipping line in advance.
The calculation of free demurrage period and container detention fee must be agreed with the entrusting party in advance to avoid subsequent cost disputes. If special packaging is required for the goods, appropriate packaging materials must be selected according to the type of goods to ensure that the goods are not damaged during transportation.
In addition, the time node of title transfer must be noted, and the endorsement transfer of the bill of lading must be completed in time after the goods are declared for export to ensure that the entrusting party can take delivery smoothly.
If there is cargo rejection or space shortage, timely communication with the shipping line is required to adjust the transportation plan and avoid delivery delay. Meanwhile, all logistics-related vouchers must be retained for future inspection.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
In the case of agency exports without tax refund declaration, attention must be paid to tax compliance requirements. If the entrusting party waives the tax refund, it is necessary to confirm whether it is necessary to be deemed as domestic sales for taxation.
According to the latest regulations of the State Taxation Administration in 2026, if agency export goods are not declared for tax refund and the exchange is not collected within the specified time limit, they may be deemed as domestic sales for taxation, and value-added tax and additional taxes and fees shall be paid.
In addition, attention must be paid to the compliance of related party transactions. If there is a related party relationship between the agent and the entrusting party, it is necessary to ensure that the transaction price meets the arm's length principle, avoiding adjustments by tax authorities.
Meanwhile, all tax-related vouchers must be retained, including agency export agreements, exchange collection slips, customs declaration forms, etc., for future tax inspection.
If the entrusting party chooses VAT deferral, communication with the local tax authority must be carried out in advance to ensure compliance with relevant requirements.
In addition, attention must be paid to the issue of non-resident enterprise withholding tax. If the entrusting party is an overseas enterprise, withholding tax must be paid in accordance with relevant regulations.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
In the case of agency exports without tax refund declaration, compliance with exchange payment and receipt is particularly important. If the entrusting party collects exchange by itself, it is necessary to ensure that the exchange collection path meets relevant regulations, avoiding situations such as money laundering or capital backflow.
If the agent collects exchange on behalf, the transfer must be completed within 3 working days after exchange collection, and transfer vouchers must be retained for inspection.
In addition, attention must be paid to the parsing of SWIFT messages to ensure that the message information is consistent with the information on the customs declaration form.
If CIPS cross-border RMB payment is used, it is necessary to ensure that the payment path meets relevant requirements, avoiding payment failures. Meanwhile, attention must be paid to the optimization of exchange settlement rate, selecting an appropriate settlement time to reduce exchange rate difference losses.
If there is a subsequent overdue exchange collection, timely communication with the entrusting party is required to ensure that exchange is collected within the specified time limit, avoiding being deemed as non-compliance. Meanwhile, all exchange payment and receipt related vouchers must be retained for future inspection.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
In the case of agency exports without tax refund declaration, the stipulation of contract terms is particularly important. It is necessary to clarify the responsibility division related to tax refunds in the agency export agreement, including the responsibility of tax refund waiver, the responsibility of document filing, the responsibility of tax risks, etc. Meanwhile, the time node of title transfer must be clarified to avoid title disputes.
If L/C transactions are involved, attention must be paid to the issue of L/C soft clauses, ensuring that the L/C terms are consistent with the agency export agreement.
In addition, attention must be paid to the fallback of force majeure clauses, avoiding delivery delay or incomplete documents due to force majeure. If a bank guarantee is needed, it is necessary to ensure that the content of the guarantee meets relevant requirements, avoiding invalid guarantees.
If there are subsequent disputes, professional legal advisors must be consulted in time to ensure that their legitimate rights and interests are protected. Meanwhile, all contract-related vouchers must be retained for future litigation or arbitration.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
In the case of agency exports without tax refund declaration, the key points of customs on-site inspection are different.
Customs will focus on verifying the consistency of goods name, quantity and customs declaration form, as well as the authenticity of the agency agreement. In addition, the authenticity of the seal will be checked to ensure that the goods have not been opened or replaced.
If container stuffing inspection is required, timely communication with customs is needed to determine the time and location of the inspection. Meanwhile, necessary tools and personnel for the inspection must be prepared to ensure smooth inspection.
If the goods involve X-ray inspection, it is necessary to ensure that the placement of the goods meets the inspection requirements, avoiding abnormal inspection results.
If the goods need to be inspected for appraisal, timely communication with customs is needed to determine the inspection institution and process. Meanwhile, all inspection-related vouchers must be retained for future inspection.
If problems occur during inspection, timely communication with customs is required to provide corresponding supporting materials to ensure smooth inspection.
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
In the case of agency exports without tax refund declaration, the compliance of document filing is particularly important. Document filing must be completed within 15 days after the goods are declared for export, including agency export agreements, exchange collection slips, copies of customs declaration forms and other materials.
Meanwhile, it is necessary to ensure that the content of document filing is consistent with the information on the customs declaration form, avoiding document inconsistency.
In addition, attention must be paid to the consistency of four flows (goods flow, capital flow, document flow, contract flow).
If there is a capital backflow, corresponding supporting materials must be provided to ensure the rationality of capital backflow. Meanwhile, all document filing related vouchers must be retained for future tax letter inquiry inspection.
If there is a subsequent tax letter inquiry, timely sorting of the full set of transaction vouchers, including agency export agreements, exchange collection slips, customs declaration forms, contracts, etc., is required to ensure the inspection passes. If problems occur during the inquiry, timely communication with the tax authority is required to provide corresponding supporting materials, avoiding being deemed as non-compliance.