Is Foreign Exchange Verification Mandatory for Transshipment Trade?
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I am the financial manager of a foreign trade company specializing in Southeast Asian transshipment trade. Recently, I am handling a shipment of goods from Malaysia, transshipped via Hong Kong to Europe, involving an amount of 5 million RMB. The customs declaration has been submitted, but the foreign exchange has not been received yet.
My finance colleague mentioned the need for foreign exchange verification, but I'm not entirely sure if verification is mandatory for transshipment trade. I previously heard that some companies faced foreign exchange retention due to non-verification.
I would like to inquire: Is corporate verification actually required for transshipment trade? If it is mandatory, what is the specific process? Are there any particular compliance points that require special attention?
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
Whether transshipment trade requires corporate foreign exchange verification must be determined based on the latest policies from the State Administration of Foreign Exchange (SAFE) for 2026 and the company's actual business model. According to the *Guidelines for Foreign Exchange Administration of Goods Trade* (2026 Revised Edition)，**the paper verification form for transshipment trade has been abolished，but foreign exchange receipts and payments still require registration in the "Enterprise Directory for Trade Foreign Exchange Receipts and Payments" and verification through the "Goods Trade Foreign Exchange Monitoring System"**. The core difference lies in the shift from "transaction-by-transaction verification" to "aggregate verification + dynamic monitoring." The operational logic is deconstructed from the entire chain below:
### I. Details of Pre-Document Review1. **Customs Declaration Forms and Transshipment Trade Filing**: Submission of the import customs declaration (issued by the import location customs)，the export customs declaration (issued by the transshipment location customs)，and proof of Hong Kong transit warehouse (if involving transit through a third location) is required. The "Terms of Delivery" on the customs declaration forms must reflect "FOB" or "CIF" (transshipment trade requires proof that the goods are not for domestic consumption and should be separately marked as "transshipment").2. **Foreign Exchange Receipts and Payments Documents**: When receiving foreign exchange，the remark "transshipment trade" must be included，and the source of funds must match the overseas payer (e.g。Malaysia-Hong Kong-Europe requires matching three sets of receipt/payment records). Avoid fund flows involving "split receipt of foreign exchange" or "lacking actual transaction background."3. **Proof of Title Documents**: Provide records of bill of lading endorsement transfers (e.g。if a Hong Kong company acts as an intermediary，it must show the original bill of lading holder transferring title to the transshipment enterprise). This avoids being identified as "fictitious transshipment."
### II. Core Stage Linkages1. **Matching Foreign Exchange Receipts with Customs Declarations**: Enterprises must complete the declaration of foreign exchange income within 15 working days after goods declaration. The *Transshipment Trade Foreign Exchange Receipts and Payments Status Form* must be filled in the "Goods Trade Foreign Exchange Monitoring System." The system automatically verifies the match between customs declaration amounts and foreign exchange receipts/payments (e.g。amount discrepancy must not exceed ±5%).2. **"Four Flows Alignment" Verification**: Ensure complete consistency among the "contract flow" (transshipment agreement signed with the Hong Kong intermediary)，"logistics flow" (pick-up order from the transit warehouse)，"funds flow" (foreign exchange receipt/payment records)，and "document flow" (customs declaration forms). Avoid triggering abnormal SAFE audits due to missing "three flows alignment."3. **Handling Special Circumstances**: If goods are detained at the transit location for over 90 days，submit a *Transshipment Trade Extended Receipt of Foreign Exchange Explanation* to SAFE in advance，explaining the reasonable reasons for detention (e.g。port congestion，destination port policy adjustments). This prevents being placed on a watchlist due to "overdue non-receipt of foreign exchange."
### III. Contingency Plans and Compliance Implementation1. **Response to Data Reporting Errors**: If the discrepancy between foreign exchange receipt/payment amount and customs declaration amount exceeds ±5%，apply for a "discrepancy adjustment" at the designated foreign exchange bank within 3 working days after receiving the funds. Submit a *Discrepancy in Foreign Exchange Receipt Explanation Letter* with supporting documents (e.g。bank statement，trade contract) to avoid triggering a SAFE investigation due to "declaration errors."2. **Tax and Foreign Exchange Coordination**: Value-added tax (VAT) for transshipment trade must be declared at a "zero rate" (new policy for 2026). However，ensure the input invoice matches the export customs declaration in product name and quantity. Avoid tax audits due to "abnormal input tax credit," which could subsequently affect the foreign exchange verification progress.3. **Long-term Compliance Loop**: It is recommended that enterprises establish a "Transshipment Trade Foreign Exchange Ledger," recording daily receipt amounts，corresponding customs declaration numbers，and goods flow direction. Conduct self-inspections quarterly，focusing on risk points such as "receiving foreign exchange without a customs declaration" and "mismatch between receipts and customs declarations." Ensure data consistency with SAFE's "off-site verification."
### IV. Final Conclusion**Transshipment trade enterprises still need to complete foreign exchange receipt and payment verification，but the traditional "verification form" is not required.** The key points are: ① Ensure "four flows alignment"，② Retain logistics and proof of title documents from transit countries/regions，③ Complete registration in the SAFE system's "Enterprise Directory for Trade Foreign Exchange Receipts and Payments" and file the *Transshipment Trade Foreign Exchange Receipts and Payments Status Form*. It is recommended that enterprises prioritize simplifying the process through the "Trade Foreign Exchange Receipts and Payments Facilitation Pilot Program" (new for 2026). Eligible enterprises can enjoy "exemption from authenticity review" and directly proceed with subsequent formalities based on customs declarations and foreign exchange receipt/payment documents.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
When handling transshipment trade customs declarations and verification, pay close attention to the consistency of the "Place of Origin in China" and "Destination in China" fields on the customs declaration form (if it is non-bonded zone transshipment, the "transshipment trade" code must be displayed). Avoid SAFE questioning "domestic receipt of foreign exchange" due to code errors.
If goods transit through a bonded warehouse, ensure the *Goods Temporary Storage Certificate* issued by the transit warehouse includes a "not imported/not exported" declaration. Otherwise, it may be considered "domestic receipt of foreign exchange," requiring re-declaration.。
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
The logistics route for transshipment trade must ensure "title does not land," meaning the goods are controlled by a third-party logistics company throughout the journey from the port of loading to the port of destination (e.g., a through bill of lading from COSCO Shipping or Maersk).
Avoid being unable to prove "goods did not enter domestic consumption" during SAFE audits due to "missing title transfer nodes." It is recommended to select international freight forwarders with "cross-border logistics title endorsement" qualifications to ensure the bill of lading can be directly transferred to the transshipment enterprise's name.。
RobertYears of service：6Customer Rating：5.0
Warehouse Management AdvisorStart a Chat
The 2026 VAT policy for transshipment trade allows "VAT deferral," but "input tax invoice certification" must be completed before the goods leave the country, and the deferral period must not exceed 90 days.
If goods cannot be transshipped on time due to destination port policy adjustments, apply for "deferred tax refund" with the tax authority before the deadline. Avoid being identified as a "domestic sale" due to "completed input tax credit," which could subsequently trigger foreign exchange verification anomalies.。
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
The core of foreign exchange verification is "matching receipts and payments." If a company receives foreign exchange through an offshore account, ensure the offshore account's bank matches the "offshore entity filing information" in SAFE's records.
When receiving funds, include the remark "transshipment trade + transit location" (e.g., "MALAYSIA-HONGKONG-EUROPE"). Avoid fund freezing due to "mismatch between offshore entity name and filing."。
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
If transshipment trade involves "offshore resale," clearly specify the "goods ownership transfer node" in the *Offshore Resale Contract* (e.g., the bill of lading endorsement date is the ownership transfer date).
The contract amount must exactly match the foreign exchange receipt/payment amount. If there is a discrepancy between the contract amount and the receipt amount, provide an "exchange rate fluctuation explanation" or a "third-party price appraisal report" during SAFE audits.。
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
Export tax refund audits should focus on verifying the consistency between "transshipment trade foreign exchange receipts and tax refund claims." If a company has completed the tax refund but not the foreign exchange verification, it may be identified as "fraudulent tax refund."
It is recommended to complete foreign exchange receipt/payment verification within 30 days after filing the tax refund claim. Ensure "tax refund data" and "foreign exchange data" are bidirectionally matched in both the tax system and SAFE's system to avoid contradictory situations like "tax refund not received but foreign exchange verified."。