What compliance conditions must be met for export tax refund of goods exported via overseas agent transportation
Importing from China?
Need help with sourcing, customs or shipping?
Your China Import Partner
Reliable sourcing and import agency services.
I work for a foreign trade enterprise exporting small household goods. Recently, in order to save ocean freight costs, we have switched to an overseas agent designated by the customer to arrange the ocean transportation segment, and we are only responsible for domestic trailer transportation and customs declaration.
We used to arrange the whole transportation process by ourselves and have successfully handled export tax refunds for several years. After changing the mode this time, our financial staff is not sure whether this situation meets the tax refund requirements, worrying that incorrect document submission will lead to letter verification from the tax authority, or even direct rejection of tax refund, which will make us lose more than ten percent of the tax refund cost.
We dare not finalize the cooperation for now for fear of problems. I would like to ask whether we can handle export tax refund normally under this overseas agent transportation situation, how to operate to get the tax refund compliantly and smoothly, and what materials need to be prepared in advance?
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
First of all，clarify the basic rules. Many enterprises mistakenly believe that they must arrange the whole transportation process independently to be eligible for tax refund. In fact，as long as the three core conditions are met: the goods are actually departed from the country，the ownership of the goods belongs to the export enterprise，and customs declaration and foreign exchange collection are completed normally，no matter whether the ocean transportation segment is arranged by domestic or overseas agents，it meets the basic requirements for export tax refund，and there is no restriction at the policy level.
For the pre-document review link，the core is to confirm the preparation information of the ocean bill of lading. Agree with the overseas agent in advance that the shipper on the bill of lading must show the full name of the export enterprise，and cannot directly show the buyer or the overseas agent itself. At the same time，require the other party to provide the agency transportation agreement with official seal，and keep the payment voucher or statement of ocean freight.
For the connection of core nodes，after the goods are declared for export，enter the information into the tax refund declaration system normally，ensure that the information of the bill of lading shipper，the operating unit on the customs declaration form，and the foreign exchange collection subject are consistent. After completing the declaration，sort out the filing files as required. If there is an error in the shipper information on the bill of lading，you should require the overseas agent to amend the bill immediately，and cannot declare with the wrong bill of lading directly.
For abnormal contingency plans and compliance implementation，if letter verification is triggered after declaration，supplementary provision of goods ownership transfer certificate and agency agreement can explain the actual situation. Finally，all filing documents must be kept for no less than 5 years，conduct a tax refund compliance self-inspection every six months，then you can stably enjoy the export tax refund policy without abnormal problems.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
When handling export tax refund, it is necessary to meet the verification requirements of four-stream consistency, which refers to contract flow, goods flow, capital flow and invoice flow. Under the overseas agent transportation mode, the transportation segment in the goods flow needs to be clearly split, and domestic segment transportation vouchers, ocean segment agency agreements and payment vouchers all need to be kept and filed.
For tax authority letter verification, you need to sort out the voucher chain of the whole business process in advance to prove the authenticity of the export business and the absence of capital return. In the case of cross-month declaration, you need to complete foreign exchange collection before the deadline of the export tax (exemption) refund declaration period.
If you meet the conditions of deemed foreign exchange collection, you need to fill in the deemed foreign exchange collection declaration form as required to avoid the cancellation of tax refund qualification due to overdue declaration. Document filing shall ensure that the information of all documents matches, and the export date on the customs declaration form, the voyage number and the ship name on the bill of lading shall be consistent, and no information deviation shall occur, otherwise an early warning will be triggered.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
In the export customs declaration link, both the operating unit and the consignor unit shall be filled in according to the actual situation, and the consignor unit shall not be filled in incorrectly just because of overseas agent transportation. If the overseas agent requires the shipper on the bill of lading to be filled in as itself, the domestic shipper on the customs declaration form still needs to retain the name of the export enterprise and cannot be changed at will.
Under the integrated customs clearance mode, the declaration requirements of all ports across the country are unified, and there will be no additional declaration requirements just because of overseas agent transportation, but you need to note the relevant information of the transportation agent in the remark column of the customs declaration form as required to avoid doubts in the price verification process. If there is a declaration error leading to mismatched document information, you need to delete the original declaration and re-declare in time, and adjust the relevant information to avoid affecting the subsequent tax refund process.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Under the overseas agent transportation mode, you need to agree on the preparation requirements of the bill of lading with the overseas agent in advance, clearly require that the shipper shows the name of the export enterprise, and the consignee and notifying party are filled in according to the buyer's requirements. If the overseas agent has issued the bill of lading and the shipper information is wrong, you need to arrange the amendment of the bill in time, and the party bearing the cost of the amendment can be agreed in the agency agreement in advance.
You need to keep all communication records related to booking, container release and bill of lading, so as to avoid being unable to provide vouchers to prove the authenticity of the business when abnormal situations such as container rollover and port change occur later. For the overseas agent transportation mode with ocean freight collected at destination, you need to keep the agreement clauses of ocean freight collection at destination as one of the tax refund filing materials to prove the authenticity of the transportation arrangement.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
The ocean freight expenditure of overseas agent transportation belongs to the normal operating cost of the export enterprise, and can be deducted before enterprise income tax according to regulations. If the ocean freight is directly paid to the overseas agent by the buyer, and the export enterprise does not need to bear this cost, you need to explain this situation in the tax refund materials and keep a copy of the buyer's payment voucher to avoid the tax authority questioning the amount of foreign exchange collected.
If the VAT deferral method is used to handle the import VAT of the destination country, you need to keep the relevant vouchers of the deferral, which does not affect the handling of domestic export tax refund, and only need to prove the authenticity of the business. There is no situation that the tax base of export tax refund is affected because the ocean freight is collected by the overseas agent. The export tax refund is still calculated according to the FOB price of the exported goods, which meets the policy requirements.
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
In the foreign exchange collection link, overseas agent transportation does not affect the normal compliance requirements for cross-border foreign exchange collection. Export enterprises need to handle foreign exchange collection according to the actual total transaction value of the goods, and complete the foreign exchange collection verification as required no matter which party pays the ocean freight.
If RMB cross-border payment is adopted, the customs declaration number of the exported goods shall be clearly marked in the foreign exchange collection message to facilitate the verification of the bank and the foreign exchange administration. If the ocean freight is deducted from the payment for goods, you need to keep the deduction agreement and calculation details to prove the rationality of the foreign exchange collection difference, so as to avoid being judged as abnormal foreign exchange collection, which will affect the normal handling of export tax refund.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
You need to clearly stipulate in the trade contract with the overseas buyer that the ocean transportation segment is arranged by the overseas agent designated by the buyer, with clear division of relevant responsibilities, so as to avoid unclear rights and responsibilities affecting the authenticity identification of export tax refund after cargo transportation loss occurs.
You need to sign a written agency transportation agreement with the overseas agent, which clearly stipulates the service scope, cost bearing and bill of lading preparation requirements of the agent, so that there is evidence to follow when disputes arise. If the letter of guarantee release mode is adopted, you need to clarify the issuing subject of the letter of guarantee and keep the original of the letter of guarantee, so as to avoid being identified by the tax authority as not actually exported due to unclear transfer of goods ownership, which will affect the tax refund process.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
For the export mode where the buyer designates overseas agent transportation for a long time, you can adjust the trade terms to FOB terms, clarify the division of responsibilities for domestic and ocean transportation segments, and match the corresponding tax refund accounting method, which will not affect the amount of tax refund. Under the FOB mode, the export tax refund is calculated according to the FOB price, and the ocean freight part does not participate in the tax refund calculation, which meets the policy requirements and will not cause compliance problems.
You can regularly compare the comprehensive costs of independent whole-process transportation and buyer-designated overseas agent transportation, including tax refund impact, operation cost, capital occupation cost, etc., and dynamically adjust the transportation mode to ensure that the overall income of the enterprise is maintained at a reasonable level.