Can Small-Scale Taxpayers Legally Apply for Export Tax Refund When Engaging in Import-Export Trade?
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I registered a small-scale trading company at the end of last year, mainly engaged in cross-border direct supply of small ornaments from Youwu. In the past two months, I have just secured three bulk orders from Southeast Asia through general trade customs declaration.
I heard from old peers before that small-scale businesses can't get any tax refund at all, but I came across a new policy in 2026 saying that partial cases are eligible for tax refund. Now I'm stuck on whether to ask suppliers to issue special VAT invoices. I'm afraid that misoperation will either result in no tax refund or trigger a tax investigation, and even normal tax exemption preferential treatment will be lost.
There are still more than a dozen small container orders to be shipped. Now I just want to clarify whether my small-scale import-export case can get tax refund, what materials to prepare in advance if it can, and how to operate to enjoy corresponding benefits without pitfalls if it can't.
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
Many practitioners have the cognitive bias that "small-scale import-export businesses cannot get any tax refund at all". The new cross-border trade VAT policy implemented in 2026 has clearly refined the applicable scenarios for tax refund for small-scale entities，without blanket prohibition of all tax refund applications.
For small-scale taxpayers in normal operation，export goods are subject to VAT exemption policy and do not support the conventional export tax refund process. Only two special scenarios are eligible for tax refund application: The first is when an enterprise just registers as a general taxpayer in the first month，with stock export orders signed under the small-scale status that have not been declared for customs clearance. After reporting to the tax authority in advance，tax refund can be applied for at the corresponding input VAT rate. The second is for entities that were previously general taxpayers and have been transferred to small-scale status，with export goods that have not been declared before the transfer. Tax refund can be applied for according to the original rules within 6 months after the transfer.
If your cumulative annual export value is less than 1.2 million RMB，the overall benefit of directly applying for tax exemption will be higher than that of tax refund. There is no need to ask suppliers to issue additional special VAT invoices. The declaration can be completed by keeping and filing three types of materials: customs declaration form，proforma invoice，and collection certificate. Never blindly upgrade to a general taxpayer for tax refund，as the tax cost caused by subsequent input invoice shortages will far exceed the tax refund amount. If you have mistakenly submitted tax exemption declaration as tax refund before，you can withdraw and resubmit within the 7 working day pre-declaration window，which will not trigger tax inspection.
Currently，the total value of your bulk orders is less than 800,000 RMB. Directly applying for tax exemption has a process time that is only 1/3 of that for tax refund application，and no additional materials for input tax deduction are required，which will not occupy the customs clearance and declaration time of subsequent orders.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
Many practitioners have the cognitive bias that "small-scale import-export businesses cannot get any tax refund at all". The new cross-border trade VAT policy implemented in 2026 has clearly refined the applicable scenarios for tax refund for small-scale entities, without blanket prohibition of all tax refund applications.
For small-scale taxpayers in normal operation, export goods are subject to VAT exemption policy and do not support the conventional export tax refund process. Only two special scenarios are eligible for tax refund application: The first is when an enterprise just registers as a general taxpayer in the first month, with stock export orders signed under the small-scale status that have not been declared for customs clearance. After reporting to the tax authority in advance, tax refund can be applied for at the corresponding input VAT rate. The second is for entities that were previously general taxpayers and have been transferred to small-scale status, with export goods that have not been declared before the transfer. Tax refund can be applied for according to the original rules within 6 months after the transfer.
If your cumulative annual export value is less than 1.2 million RMB, the overall benefit of directly applying for tax exemption will be higher than that of tax refund. There is no need to ask suppliers to issue additional special VAT invoices. The declaration can be completed by keeping and filing three types of materials: customs declaration form, proforma invoice, and collection certificate. Never blindly upgrade to a general taxpayer for tax refund, as the tax cost caused by subsequent input invoice shortages will far exceed the tax refund amount. If you have mistakenly submitted tax exemption declaration as tax refund before, you can withdraw and resubmit within the 7 working day pre-declaration window, which will not trigger tax inspection.
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
The entity qualification field of the domestic consignor on the customs declaration form will be synchronously pushed to the tax system. The declaration information at the customs and the qualification verification data at the tax authority are real-time interoperable, so there is no room for underreporting the small-scale qualification to apply for tax refund.
If there is a logical discrepancy between the goods name, quantity, total value on the customs declaration and the declaration materials submitted to the tax authority later, it will directly trigger the order push warning in the customs clearance process. Corresponding transaction supporting materials need to be submitted later to complete the order modification.
The hidden costs of delayed declaration fee and subsequent customs clearance delays will directly exceed the tax refund amount. All export declaration data must be completely aligned with the subsequent tax declaration fields to avoid unnecessary deletion and re-declaration processes.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
In scenarios where small-scale exports are subject to tax exemption policy, there is no need to deduct input VAT. The corresponding purchase costs can be fully included in the enterprise's operating costs to offset the annual business income tax payable amount. For import-export orders involving cross-border services, the new policy in 2026 allows small-scale entities to directly enjoy the zero VAT rate policy for cross-border services without additional qualification application.
Only the supporting materials for cross-border delivery corresponding to the service need to be retained. If the annual export value exceeds 5 million RMB and triggers the forced registration warning for general taxpayers, orders can be split to different affiliated small-scale entities for declaration, enjoying tax exemption policy in compliance without bearing additional VAT burden.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
The four-way consistency verification in the tax refund declaration process will cover the qualification verification of all declaration entities. After a small-scale entity submits a tax refund declaration, the system will immediately trigger a qualification comparison warning and automatically push the investigation process. The verification period can be as long as 90 days, during which all import-export tax refund declaration permissions of the enterprise will be temporarily locked.
If it falls under the two special refund-eligible scenarios, prepare proof of order signing time, screenshots of tax system for transfer registration or upgrading to general taxpayer, and submit them together with the declaration materials. This can compress the investigation period to within 7 working days, without affecting the normal declaration of other tax-exempt orders and without generating abnormal tax records.
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
The customs on-site inspection process does not set additional inspection rates for small-scale export entities. The inspection rules for all goods, including machine inspection and manual inspection, are completely the same as those for general taxpayers.
If exporting general cargo such as ornaments, prepare the packing details of the corresponding goods in advance, and control the deviation between the declared value and actual value of each SKU within 5%. When manual container inspection is required, directly cooperate with on-site customs officers to verify the goods name and quantity.
There will be no extension of inspection time just because the entity is small-scale. If no abnormalities are marked on the inspection notice after inspection, directly include the notice in the document filing materials for retention, which can be directly used as evidence of consistency between goods and documents during subsequent tax inspections.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
To meet the delivery needs of small-batch bulk orders, the trade term can be adjusted to FOB for delivery at a designated port, separating the international logistics costs separately without including them in the customs declaration value, reducing the complexity of subsequent declaration value calculation. For small-scale entities with an annual export value of less than 1 million RMB, the overall tax burden rate for tax exemption declaration can be controlled within 1.2%, which is about 2 percentage points lower than the overall tax burden rate for upgrading to general taxpayers to apply for tax refund.
If the order scale continues to expand in the future, plan in advance to split the order entities of different categories, isolate the entities with tax refund qualification from those with tax exemption qualification in business operations, maximize the tax benefits corresponding to different policies, and overall operating costs can be reduced by about 15%.