Full Process of Partial Tax Refund Under Export Agency in 2026, Complete Practical Guide for Compliant Declaration of General Goods

2026 Rule Adjustment for Partial Tax Refund Under Export Agency

Partial tax refund under export agency applies to declaration scenarios where part of the goods in the same export batch meets tax refund conditions,while the rest are subject to tax exemption policy or deemed domestic sales policy.New declaration rules are implemented at all national ports in 2026,with cross-port declaration authority fully opened,and requirements for HS code classification and document matching are greatly improved.Previously widely adopted operations such as combined declaration and vague classification by enterprises have triggered risk control alerts,and cases of tax refund being withheld and fines imposed rose by 37% year on year.

Full Practical Operation Process of Partial Tax Refund Under Export Agency

The core of partial tax refund declaration is product category splitting and document matching,all operations shall be completed within 30 days after customs declaration and export,otherwise the tax refund qualification will be lost.The specific operation steps are as follows:

• Complete HS code verification of all categories 7 days before shipment: submit declaration elements of all goods including brand,model,material,usage synchronously,the agency party completes splitting and marking of categories applicable to tax refund,tax exemption and deemed domestic sales.For mechanical and electrical products,China Inspection verification shall be completed in advance,and the latest version of MSDS shall be provided for chemical products.
• Complete document matching synchronously during customs declaration: mark the tax refund category separately in the remarks column of the customs declaration form,keep the corresponding special VAT invoice,purchase contract and warehousing documents,FOB price calculation shall exclude international freight,insurance premium and overseas commission to avoid rejection by customs price verification.
• Submit through separate channels at tax refund declaration stage: the tax refund category goes through the dedicated export tax refund declaration channel,upload the export agency certificate and foreign exchange collection receipt synchronously,complete tax exemption filing for tax exemption categories,normally calculate output tax for categories under deemed domestic sales policy.The three types of declaration shall be completed synchronously within 30 days after customs export.
• Retain full set of documents for future reference after the operation: all declaration documents,communication records and logistics vouchers shall be kept for 10 years,which can be retrieved directly when cooperating with spot checks of tax authorities,to avoid tax refund recovery due to missing documents.

Core Risk Warning and Pitfall Avoidance Guide

In the first half of 2026,the national rejection rate of partial tax refund declaration reached 41%,main risk points are concentrated in three dimensions:

The first one is incorrect HS code classification.Some enterprises classify categories applicable to tax exemption or deemed domestic sales into high tax refund rate categories to obtain higher tax refund.Once discovered by joint inspection of customs and tax authorities,the fine amount will be 1 to 5 times of the tax refund already obtained,the enterprise will also be included in the export dishonesty list,and the inspection rate for all subsequent goods will be increased to 100%.

The second one is non-compliance with foreign exchange collection time limit requirements.The 2026 new rule clearly stipulates that full foreign exchange collection for corresponding goods must be completed within 90 days after tax refund declaration.If full payment cannot be collected on time due to reasons such as overseas customer default,the enterprise shall submit an extension application to the tax authority in advance.For enterprises that fail to apply and fail to collect foreign exchange within the time limit,the obtained tax refund will be recovered and a late payment surcharge of 0.05% per day will be imposed.

The third one is inconsistent document information.The deviation between the declared value on customs declaration form and the value on special VAT invoice shall not exceed 5%.If the deviation is too large,the customs will initiate price verification procedures,requiring the enterprise to provide transaction vouchers,cost calculation statements and other materials.Enterprises that cannot provide required materials will have their tax refund application rejected directly,and the generated demurrage fee will be borne by the declaring party.

Practical Operation Case Reference

A hardware export enterprise based in Suzhou exported a batch of goods to Germany in March 2026,including 1200 pieces of hand tools (13% tax refund rate) and 300 pieces of consumables (subject to tax exemption policy).When the enterprise declared by itself,it classified consumables into the hand tool category,applied for a tax refund of 287,000 RMB,and triggered a tax authority risk alert.The tax refund was withheld and the enterprise was required to submit a situation statement.If it was identified as tax fraud,the enterprise would face a fine of 5 times the refund amount.

After the Shanghai team of Zhongshitong took over the case,it sorted out all declaration elements of the whole batch of goods immediately,re-completed HS code classification,split tax refund and tax exemption categories,supplemented the endorsement materials of RCEP certificate of origin,adjusted the declaration content of the customs declaration form,synchronously contacted the local tax authority in Suzhou to submit compliance statement,and coordinated Shanghai Port to complete declaration form modification.The whole process was finished in 12 days,the enterprise finally successfully obtained 238,000 RMB tax refund without any fine,and the subsequent declaration pass rate reached 100%.

Cross-regional Declaration Service Support

Zhongshitong is headquartered in Shanghai,and can undertake partial tax refund declaration businesses under export agency at all national ports,completing the whole process without requiring the enterprise to send on-site representatives.The agency network covering 120 countries around the world can verify destination trade policies in advance,and adjust documents in advance in response to EU and US anti-dumping lists and RCEP tariff reduction rules,to avoid extra tax and fee expenditure.As the 2026 Christmas season is approaching,the inspection rate at EU and US ports will increase by 30%.It is recommended that enterprises submit all documents for pre-review 10 days before shipment,to avoid extra expenditure such as container detention fee and document replacement fee.Currently,the container detention fee at major basic ports in Europe and the US has reached 150 Euros per day per container,and the extra expenditure caused by insufficient preparation in advance accounts for over 12% of the total profit for most enterprises.