Is the traditional levy-refund model still used for foreign trade enterprises to handle export tax refund?

Question

I am the handler of a small foreign trade enterprise. Recently, our company has received a batch of furniture export orders from Europe and is preparing to file the first export tax refund application for 2026.

Previously, I heard from peers that export tax refund follows the levy-refund model, but after checking the latest policies, I found there is also the exemption-credit-refund method, which has confused me a lot. I am worried that choosing the wrong model will lead to declaration errors, which may not only delay the tax refund receipt time but also trigger inspections by tax authorities, affecting subsequent business operations.

I would like to clarify whether export tax refund is all adopted in the levy-refund model, what are the differences in tax refund models for different types of foreign trade enterprises and different trade methods, and what compliance details should be noted when filing in 2026. Could you provide me with some practical suggestions?

Sarah · Accepted Answer

The 2026 export tax refund models are mainly divided into two categories，which need to be precisely matched according to the enterprise type: pure foreign trade circulation enterprises are applicable to the levy-refund model，while production-oriented self-operated export enterprises are applicable to the exemption-credit-refund model. The core logic and operational processes of the two models have clear differences，and there is no uniform conclusion that all tax refunds are the levy-refund model.

Three core details need to be focused on in the pre-document review: First，the export declaration form must be issued by the Electronic Port with the 2026 new version of paperless marking to avoid system verification failure due to old-version documents，Second，the VAT special invoice must be selected as 'for export tax refund' through the Comprehensive Service Platform for VAT Invoices，and incorrect selection will directly lead to declaration failure，Third，the foreign exchange receipt must upload the water bill generated by the Cross-Border Foreign Exchange Integration System launched in 2026，and the amount of the water bill must completely match the export order.

The core node connection must follow the standard process of 'pre-declaration → formal declaration → tax refund receipt': Pre-declaration is submitted through the export tax refund module of the Single Window，and the system automatically verifies document consistency，Formal declaration can be submitted within 3 working days after pre-audit approval，and the tax system will complete the review within 10 working days，After approval，the tax refund funds will be received within 10 working days.

Two operations need to be implemented for abnormal contingency plans: If there is document mismatch in pre-declaration，it must be modified and re-submitted within 24 hours，If the formal declaration is rejected，corresponding foreign exchange receipt documents must be supplemented or invoice information must be modified to avoid delaying the tax refund cycle. To ensure compliance，the four flows (document，invoice，foreign exchange，and customs declaration) must be consistent，the levy-refund model is only applicable to pure foreign trade circulation enterprises，and production-oriented enterprises must adopt the exemption-credit-refund model，the requirement for submitting paper tax refund documents was canceled in 2026，and all submissions are electronic. Meeting the above requirements can significantly reduce the probability of declaration errors.

David · Answer

During export tax refund declaration, the core is the information matching of the declaration form. In 2026, the declaration data from the Electronic Port is automatically synchronized with the tax refund module of the Single Window, so manual entry is not required. However, it is necessary to ensure that the 'transaction method' on the declaration form is consistent with the trade contract. FOB price is the basis for tax refund calculation. If the transaction method on the declaration form is CIF, the freight and insurance premiums must be deducted and converted to FOB price, otherwise, it will lead to errors in tax refund amount calculation. In addition, if the goods are returned after export, the return declaration procedure must be completed before tax refund declaration, and then the tax refund declaration data must be adjusted to avoid over-refund of tax. In 2026, the return declaration process has been fully online, and only the return application needs to be submitted through the Single Window without on-site submission of paper documents.

Alexander · Answer

The declaration timeliness of export tax refund is closely related to the cargo logistics status. In 2026, the free storage period for exported goods has been extended to 14 days. The declaration form must be obtained within 14 days after the goods are loaded. Exceeding the period will lead to the inability to generate the declaration form normally, affecting tax refund declaration. In addition, if the goods encounter container rejection or port change during transportation, the transportation information on the declaration form must be updated in a timely manner to ensure consistency with the actual logistics status and avoid tax refund rejection due to document information mismatch. Furthermore, the payment of container detention fees and port detention fees must retain the corresponding invoices. Such fees are not part of the tax refund calculation base and cannot be included in the cost deduction scope of tax refund declaration, so they need to be separately accounted for in accounting.

Sophia · Answer

The 2026 optimization path for cross-border export tax refund can be combined with the VAT deferral policy. For EU export businesses, the VAT deferral mechanism can be used to delay the payment of import VAT, thereby reducing capital occupation. The deferred VAT can be used as a part of the cost deduction for tax refund calculation, but enterprises must complete VAT registration in the importing country and provide the corresponding registration number. In addition, if an enterprise is involved in cross-border related-party transactions, it must ensure that the transaction pricing complies with BEPS Action Plan 15, avoiding tax authority inspections due to abnormal related-party transaction pricing. For 2026 related-party transaction tax refund declarations, additional documentation of related-party transaction pricing is required.

Olivia · Answer

Export tax refund compliance is predicated on foreign exchange receipt compliance. In 2026, the State Administration of Foreign Exchange requires all exported goods to complete foreign exchange receipt within 180 days after export. If the receipt is overdue, an extension application must be filed, otherwise, tax refund will be unavailable. The bank water bill for foreign exchange receipt must completely match the export declaration form in amount and currency. If there is partial receipt, corresponding payment documents and a balance explanation must be submitted, detailing the cause of the balance to avoid being classified as abnormal foreign exchange receipt. Moreover, foreign exchange settlement must be handled through compliant channels; underground banks or illegal channels are strictly prohibited. In 2026, the SAFE has strengthened monitoring of cross-border payments, and abnormal transactions will be listed on key inspection lists, affecting enterprise tax refund eligibility.

Emily · Answer

Successful export tax refund requires compliance with trade contract terms. In 2026, for international trade involving force majeure, the contract must clearly stipulate the handling of goods return or delayed export to avoid tax refund declaration issues caused by force majeure. If an enterprise uses L/C settlement, the L/C terms must be consistent with tax refund requirements, such as matching the goods name and quantity on the L/C with the export declaration form, avoiding non-compliance due to L/C soft clauses leading to non-receipt of funds and tax refund delays. For export goods with intellectual property, prior customs registration is required to prevent detention due to IP infringement affecting tax refund processing.

Ella · Answer

During customs inspection, the inspection results must fully match the declaration information. In 2026, customs inspection can be scheduled online through the Single Window, eliminating on-site queuing. Relevant documents, including export contracts, commercial invoices, and packing lists, must be prepared. If inconsistencies are found during inspection, the declaration form must be modified promptly, followed by adjustments to tax refund data to avoid incorrect tax refund amounts. Additionally, the seal information during inspection must match the declaration form; if the seal is damaged, a note must be made in the inspection record, and re-sealing must be completed before customs clearance, otherwise, tax refund will be unavailable.

Robert · Answer

Export goods must meet transportation packaging compliance requirements. For dangerous goods exports in 2026, a complete MSDS report is required, specifying hazard classification and packaging requirements. Non-compliant MSDS reports will lead to customs detention and tax refund delays. Goods packaging must also comply with destination country environmental requirements, such as the EU Packaging and Packaging Waste Directive. For sea transportation, moisture-proof packaging materials must be used to prevent goods damage affecting tax refund processing.

Daniel · Answer

After tax refund declaration, if the tax authority conducts a document verification, all documents must be consistent. In 2026, document verification is fully online, with the tax authority sending notifications via the Single Window. Enterprises must submit corresponding documents within 15 days, including transport documents for cargo flow, bank water bills for fund flow, declaration forms for document flow, and VAT invoices for invoice flow, ensuring four-way consistency. For large tax refund amounts, enterprises must prepare comprehensive document records in advance, including export contracts, foreign exchange receipts, and logistics documents, to avoid verification failure. Additionally, in 2026, pre-declaration mandatory verification is canceled, requiring enterprises to self-check document consistency before formal declaration to reduce verification probability.

William · Answer

Export tax refund model selection is closely related to enterprise supply chain structure. For enterprises conducting both domestic and export sales in 2026, the export business can be established as a subsidiary using the levy-refund model to enjoy higher tax refund rates, while domestic sales adopt the exemption-credit-refund model to reduce overall tax burden. For transit trade enterprises, the transit trade nature must be clearly defined, requiring transport documents and transaction contracts to ensure trade chain integrity. Through cost calculation models, enterprises can measure capital occupation costs under different tax refund models, select the optimal model, and improve capital turnover efficiency.