Can an export agency company legally apply for export tax refunds after starting operations?
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I run a company that has been doing export agency business for just half a year. Previously, we only helped clients with customs declaration and logistics. Recently, a client asked if we could help them apply for tax refunds, and I am completely clueless. Our company does not have a dedicated tax position.
I previously knew that foreign trade enterprises could get tax refunds, but I did not know if agency companies could do it. Last week, an old client's order was approaching the tax refund deadline. They said if we could handle the tax refund, it would save them a lot of trouble, but I am afraid of operating incorrectly and triggering a tax audit.
I also do not know if our company's qualifications are sufficient, for example, do we need import and export rights or other licenses? Additionally, do we need to add tax refund related clauses to our agency agreement with clients? I am very panicked now, afraid of missing the client's order and stepping into compliance pitfalls. I want want to know whether our type of export agency company can actually apply for tax refunds and specifically how to do it.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
Under the current 2026 policy，eligible export agency companies can indeed apply for export tax refunds，but two core prerequisites must be met: first，having completed the filing for import and export goods consignees，second，signing a legally valid agency export agreement with the entrusting party that clearly specifies the ownership of the tax refund subject for the agency export goods. If your company currently only handles customs declaration and logistics without clarifying the tax refund subject，you need to first sort out the cooperation model with the entrusting party.
In the pre-review stage of the full process，three types of documents need to be checked: the entrusting party's supply contract，the corresponding VAT special invoice for the goods (which must be issued to the agency company)，and the application materials for the "Proof of Goods Exported by Agent." Here，it is necessary to strictly confirm that the purchaser on the invoice is completely consistent with the agency company. If the entrusting party issues the invoice directly to themselves，it cannot serve as a compliant voucher for agency tax refunds.
In connecting the core nodes，you must issue the "Proof of Goods Exported by Agent" through the Electronic Tax Bureau within 30 days after the goods are declared for export，and submit materials such as this proof，the customs declaration form，the agency agreement，and the foreign exchange collection voucher to the competent tax authority. In 2026，the tax system has achieved automatic matching between national clearance data and the tax refund system. If document information does not match，the system will issue an immediate warning，and corrections must be completed within 3 working days.
Regarding contingency plans，if a tax verification letter is encountered，you must promptly cooperate by providing a full set of materials such as proof of cargo ownership，logistics trajectories，and capital flow records. In 2026，some regions launched an intelligent verification tool for pre-declaration of export tax refunds，which can screen for document mismatches and missing information in advance. It is recommended to prioritize using this tool to reduce declaration risks.
After final compliance implementation，the full set of documents must be filed for 10 years，including agency agreements，customs declaration forms，foreign exchange collection vouchers，and VAT special invoices. It should be noted that if the agency company only charges an agency fee and does not actually bear the title to the goods，you must strictly declare under the agency model and must not falsely apply for tax refunds in your own name，otherwise you will face tax penalties and credit rating impacts.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
The issuance of the "Proof of Goods Exported by Agent" must match the customs declaration form information completely. In 2026, the customs integrated system has achieved automatic association between the proof and the customs declaration form.
If the operating unit is filled in incorrectly, the system will issue a warning within 1 working day after customs declaration is completed, and you must promptly handle the deletion and re-declaration. For on-site inspections of high-risk goods, prepare materials such as the agency agreement, supply contract, and packing list in advance to ensure compliant materials can be provided quickly during inspection.
If a price review dispute arises, provide materials such as proof of transaction price for the goods and market condition reports to assist customs in completing the price review process and avoid affecting the timeliness of tax refund document issuance. Additionally, note that the "Trade Mode" field on the customs declaration form must be filled in as "Entrusted Agency Export" and not "General Trade," otherwise agency tax refunds cannot be processed.
Some agency companies may confuse the declaration methods for self-operated exports and agency exports. Self-operated exports must be declared in their own name, with invoices issued to themselves, while agency exports must be declared in the name of the entrusting party, with invoices issued to the agency company.
In 2026, Customs launched a fast track for agency export declarations, which can shorten clearance time by 30%, but agency filing must be completed in the system in advance, otherwise this channel cannot be used. Additionally, if it involves cross-border e-commerce agency exports, pay attention to the consistency of declaration data from the e-commerce platform with tax refund documents to avoid refund failures caused by data discrepancies.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
International logistics operations directly affect the progress of tax refunds. In 2026, the free storage period for international sea transport was uniformly adjusted to 14 days. You need to arrange declaration time reasonably to avoid demurrage charges, while keeping a full set of logistics vouchers as tax refund filing materials.
The consignee on the bill of lading must be consistent with the subject of the "Proof of Goods Exported by Agent." If the bill of lading consignee is the entrusting party, you need to note "To Order" on the bill of lading and complete the endorsement to ensure cargo title belongs to the agency company. If abnormalities such as port changes or container roll-offs occur, update the customs declaration information promptly and inform the tax authority simultaneously to avoid rejection of the tax refund due to document discrepancies.
Some clients may require the agency company to collect payments on their behalf. A formal agency collection agreement must be signed and filed with the tax authority to ensure the collection subject is consistent with the agency company.
Additionally, in 2026, the CIPS system covered more than 120 countries globally, enabling real-time arrival of cross-border RMB receipts and payments. Compared to the SWIFT system, the fees are lower.
It is recommended to prioritize using this system for receipt and payment operations to reduce exchange rate risks. If there is a delay in receiving foreign exchange, communicate with the entrusting party promptly and apply for deferred declaration with the tax authority to avoid affecting tax refund timeliness.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
Tax refunds for export agency companies must comply with international tax compliance requirements. If cross-border related party transactions are involved, pricing filing must be done in advance to avoid being identified as a BEPS risk. In 2026, some regions introduced a VAT deferral policy for agency tax refunds, where the agency company can temporarily defer paying import VAT and offset it when applying for tax refunds after the goods are exported.
Deferral application materials must be submitted to the competent tax authority in advance. Additionally, if the entrusting party is an overseas enterprise, you need to withhold and remit the 10% withholding tax on non-resident enterprises, otherwise the tax refund declaration cannot be completed.
It is recommended to conduct a tax compliance audit once a year to screen for potential tax risks, such as whether the tax refund clauses in the agency agreement are compliant and whether invoice issuance meets requirements. If a tax audit occurs, promptly provide the full set of documents and business proof materials to assist the tax authority in completing the review.
Additionally, note that the declaration deadline for export tax refunds is the VAT tax declaration period before April 30th of the year following the export of the goods. Tax refunds cannot be applied for after the deadline.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
The compliance of cross-border receipts and payments is one of the core prerequisites for tax refunds. In 2026, the State Administration of Foreign Exchange launched a filing system for agency export receipts and payments.
Agency companies must complete filing in advance to collect payments for entrusting parties. The information in SWIFT messages must be completely consistent with the customs declaration form and the "Proof of Goods Exported by Agent."
If discrepancies in goods quantity or amount occur, it will trigger the tax authority's verification letter process. Additionally, pay attention to the compliant management of offshore accounts to avoid tax risks caused by using offshore accounts for receipts and payments.
If third-party agency collection is involved, a formal agency collection agreement must be signed and filed with the tax authority to ensure consistency of capital flow. In 2026, the monitoring system of the State Administration of Foreign Exchange has achieved networking with the tax system.
If discrepancies are found between receipt and payment information and tax refund documents, an automatic warning will be issued, and timely adjustments and submission of explanatory materials are required. Additionally, pay attention to optimizing the settlement exchange rate; you can lock the exchange rate through methods like forward settlement to reduce exchange rate losses.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
The agreement between the export agency company and the entrusting party must clarify legal clauses related to tax refunds, including the tax refund subject, fund allocation, and liability for breach of contract, to avoid subsequent disputes.
If it involves Letter of Credit (L/C) business, it must be clearly stated in the L/C that the "Proof of Goods Exported by Agent" can serve as a payment voucher to avoid discrepancies between the L/C and tax refund documents. Additionally, if a cargo title dispute arises, issue a letter of guarantee promptly to ensure compliant disposal of the goods, while keeping all legal documents as tax refund filing materials.
It is recommended to review the agency agreement once a year to ensure compliance with the latest legal requirements, such as the relevant clauses in the "Administrative Measures for Cross-border Trade Agency" implemented in 2026.
If intellectual property protection is involved, complete the IP customs protection filing in advance to avoid refund failures caused by goods being detained. Additionally, if a force majeure event occurs, issue a force majeure certificate promptly and apply for deferred declaration with the tax authority to avoid losses caused by overdue declaration.
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
The core of export tax refund auditing is verifying the consistency of the four flows: contract flow, cargo flow, capital flow, and invoice flow. Agency companies must retain the full set of documents for filing for 10 years, including agency agreements, customs declaration forms, foreign exchange collection vouchers, and VAT special invoices.
In 2026, the tax authority's verification letter system has achieved nationwide networking. If document discrepancies are found, a verification letter notice will be issued within 5 working days, and relevant materials must be provided promptly for explanation.
If the tax refund declaration for the current month fails, a corrective declaration must be made in the following month to avoid late fees. Additionally, pay attention to cross-regional tax refunds.
If the agency company operates in multiple ports, tax refund filing must be completed in each port in advance to ensure a smooth declaration process. In 2026, some regions introduced a "deficiency-tolerant processing" policy for export tax refunds.
If there are minor flaws in the documents, the refund can be processed first and materials supplemented later. You need to understand the local policy requirements in advance.