Is Transshipment Trade Income Qualified as Export Sales?
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We are a foreign trade company mainly engaged in transshipment of electronic products. Recently we imported chip modules from Country A in Southeast Asia, then transshipped them to Country B in Europe. The financial team says this transshipment income should be handled as "export sales", but I always find it unreasonable — we do not produce these goods in China at all, how can the income be counted as export sales?
Previously, we misreported a domestic sale as export sale, resulting in recovered tax refund, so we cannot afford any mistake this time. We want to confirm whether transshipment trade income belongs to export sales, and what details we shall notice for compliance declaration.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Whether transshipment trade income belongs to "export sales" shall be judged through full-process disassembly from three dimensions: customs supervision，tax treatment and foreign exchange administration.
First，the definition of trade nature at the customs level is the core. In accordance with the special supervision requirements for "Transshipment Trade" in Chapter 22 of the 2026 Customs Statistical Commodity Catalogue issued by the General Administration of Customs of China，if goods only undergo operations such as warehousing，packaging and repackaging in the transit country (or region) without circulating in the domestic Chinese market，the customs trade mode code is "0615 Transshipment Trade". Such businesses shall state "no actual import and export" separately during declaration，so the transshipment income is essentially "overseas trade income"，which does not belong to the "export sales" defined by customs (i.e. export income settled after goods actually exit the territory). However，it shall be noted that if "0110 General Trade" is filled incorrectly in the Export Goods Declaration Form for transshipment trade，the customs may determine it as "false declaration of trade mode" and trigger inspection risks.
Second，in tax declaration，the value-added tax treatment of transshipment trade income shall be distinguished into two scenarios: if the value-added rate of goods after processing in the third country is lower than 15%，the zero-rate policy for "cross-border taxable activities" applies，and there is no need to pay value-added tax as，export sales，if the value-added rate exceeds 20%，the output tax shall be declared as "sales of goods". Enterprises shall keep transshipment contracts，certificates of origin，and warehouse documents (such as inbound and outbound receipts of Singapore port bonded warehouse) as supporting documents for "non-domestic sales"，to avoid being recognized as "issuing false export sales invoices" by tax authorities.
Finally，in the foreign exchange administration link，whether transshipment income needs to be settled depends on the declaration rules of the collecting bank. In accordance with the new regulations of 2026 CIPS (Cross-border Interbank Payment System)，if the counterparty remits funds directly to a third-country account via SWIFT message without involving the domestic foreign exchange collection account，foreign exchange verification is not required. However，if the enterprise collects transshipment payment in the name of "offshore account"，it shall mark the income as "transshipment trade income" in the "SAFE Goods Trade Monitoring System"，and complete the closed capital loop within 90 days，otherwise the "failure to declare as required" warning will be triggered.
In actual operation，enterprises shall focus on checking three points: ① Whether the "domestic destination" in the import declaration form is the "third-country transit port" (such as Port of Rotterdam)，② Whether the "destination country" in the export declaration form is consistent with the transshipment contract，③ Whether there is the situation of "collection by domestic resident individual" in the foreign exchange receipt voucher. It is recommended to keep the Transshipment Trade Income Confirmation Letter as financial voucher at the same time，to avoid tax recovery due to "inconsistency of four flows" (contract flow / logistics / capital flow / information flow) during tax inspection.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
When declaring the customs declaration form, select the code "0615 Transshipment Trade", and do not fill in "0110 General Trade" in the trade mode column, otherwise the system will automatically mark it as "abnormal declaration". The certificate of origin of transshipped goods shall be affixed with the "non-country of origin" seal of the transit country customs, to avoid being identified as "unknown origin".。
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
Transshipment trade income does not belong to "export sales income" in tax treatment, so the "exemption, credit and refund" policy does not apply, and value-added tax shall be declared as "zero-rate taxable services". If the enterprise has declared tax refund as export sales, it shall carry out "input tax transfer out" in the current value-added tax declaration form, and contact the competent tax authority to revoke the declared tax refund data.。
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
Transshipment trade foreign exchange income is not subject to mandatory settlement, and can be remitted directly to the offshore account via the "Cross-border Interbank Payment System (CIPS)". However, it shall be noted that if the funds enter the domestic settlement account, the Filing of Transshipment Trade Revenue and Expenditure Explanation must be completed within T+1 working days, otherwise the State Administration of Foreign Exchange will mark it as "abnormal funds in pending verification account".。
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
If there is shortage of goods in transshipment trade, the remark column of the import declaration form shall be marked with "more or less delivered", and submit the third-party logistics certificate (such as the shortage and surplus note issued by the shipping company) to avoid being identified as "false transshipment" due to "inconsistency between goods ownership transfer and capital flow".。
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
The core difference between transshipment trade and export sales lies in: transshipped goods do not enter the China customs supervision area, while export sales goods need to complete "export customs declaration" in China; if enterprises confuse the two, it may lead to abnormality of "export tax refund verification letter", which affects the tax refund quota of the next year.。
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
The 2026 new customs policy adds the requirement of "whole-vessel manifest visualization" for transshipment trade. Enterprises shall pass AEO certification and use the "Single Window Manifest System" to upload goods trajectory in real time, otherwise the customs will send "goods detention notice" within 3 working days.。
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
In the export tax refund audit, the matching degree between the "foreign exchange receipt verification slip" and the "export declaration form" shall be checked for transshipment trade income. If the interval between the foreign exchange receipt time and the goods export time exceeds 90 days, the Explanation of Transshipment Trade Capital Closed Loop shall be submitted, otherwise the "capital return" warning will be triggered.。