Practical Compliance Path for Applying for Export Tax Refund Under EXW Terms

Core Misconception of EXW Tax Refund: Does the Declarant Get the Refund?

In 2026 international trade practices,a large number of factory-based foreign trade enterprises frequently accept EXW (Ex Works) terms to cater to overseas buyers’ demand for logistics cost control.However,a common and costly misconception is that under EXW terms,since the buyer arranges pickup and transportation,the customs declaration responsibility is fully taken over by the forwarder designated by the buyer,leading to the enterprise being unable to obtain the export customs declaration form,and thus defaulting to waive the export tax refund right.This perception directly gives up a 13% or even higher tax refund rate,causing immediate evaporation of net profit.

It must be clarified that EXW terms only specify the point of risk transfer and the party responsible for logistics costs,and do not deprive the seller of the statutory right to apply for tax refund as the export business entity.According to the latest regulatory logic of the General Administration of Customs and the State Taxation Administration,as long as the goods actually depart the country,and the document flow,capital flow and goods flow meet the basic principle of "three-document matching",export tax refund under EXW terms is fully operable.The key lies in breaking the document barrier caused by buyer-designated logistics,which requires strong professional agency intervention capability.

Three Proven Compliance Paths for EXW Tax Refund Implementation in 2026

To get the tax refund under the EXW mode,the core is to regain the "right of customs declaration".Based on operational experience at Shanghai Port and nationwide coordinated operations,Zhongshitong has sorted out the following three battle-tested compliance paths,and enterprises can choose flexibly according to their own bargaining power:

• Path 1: Seller self-declaration and export (Recommendation rating: ★★★★★)Even if the buyer designates a trucking company,the seller can still entrust a local professional customs broker (such as Zhongshitong) to handle export declaration.In operation,the seller only needs to provide the loading information (quantity,weight,measurement) and header information provided by the buyer to the customs broker,and the customs broker is responsible for submitting data to the customs.Under this model,the "domestic consignor" on the customs declaration form is listed as the seller,the seller can successfully obtain the tax refund copy of the customs declaration form,and the tax refund process is fully independent and controllable.
• Path 2: Convert nominal export to formal trade (Recommendation rating: ★☆☆☆☆)This was a common gray-area operation in the industry in the past,which means declaring customs under the forwarder’s header,and the seller purchases the customs declaration data.However,under the strict supervision of Golden Tax Phase IV in 2026,the tax authority implements 100% system audit + manual verification on the header matching between customs declaration forms and VAT invoices.Nominal export is very likely to trigger "letter investigation" or even be identified as tax fraud,with extremely high risks.Zhongshitong strongly recommends enterprises to abandon this method.
• Path 3: Dual-header declaration (Recommendation rating: ★★★☆☆)Applicable to scenarios where the buyer is extremely strong and requires customs declaration by their designated forwarder.Through negotiation,the forwarder is required to adopt the "dual-header" model on the customs declaration form,that is,the domestic consignor is listed as the seller (for tax refund),and the production and sales unit is listed as the forwarder or actual consignor.This method requires high cooperation from the forwarder,and the customs systems of some ports have stricter review of dual headers,so the operational difficulty is increasing year by year.

Zhongshitong Practical Guide: Restructure EXW Document Flow

Choosing "seller self-declaration and export" is only the first step.The real challenge lies in coordinating data synchronization between the buyer-designated logistics provider and our customs broker.The following is the standardized operation SOP implemented by Zhongshitong for customers nationwide,to ensure that tax refund documents are 100% accurate under EXW terms:

First,Advance information sharing.3 days before cargo loading,the enterprise must request the final warehouse receipt data (SO) or loading plan from the buyer,and send it to Zhongshitong’s operation team simultaneously.Zhongshitong will immediately conduct pre-declaration review based on these data,focusing on verifying whether the HS code classification is consistent with the invoice product name,and whether the declaration elements (brand,model,material,usage) are complete,to avoid failure of customs clearance after the goods arrive at the port and high port detention costs caused by inconsistent declaration elements.

Second,Split of property right documents.Under the EXW model,the buyer usually needs to hold the bill of lading (B/L) to control pickup at the destination port.To meet tax refund requirements,Zhongshitong will coordinate with the shipping company or forwarder to issue "master bill + house bill" or directly issue House B/L by the forwarder.The master bill is given to the buyer for pickup,and the house bill or delivery order (D/O) is given to the seller for customs declaration.This document splitting technology is the key measure to resolve the property right conflict in EXW tax refund,and it relies on Zhongshitong’s strong agency network resources in Shanghai and major ports around the world.

Finally,Closed loop of foreign exchange receipt verification.The tax authority requires export enterprises to receive foreign exchange before obtaining tax refund.Under EXW terms,the payment is usually RMB spot exchange or paid through offshore accounts.The enterprise must ensure that the declared amount of foreign exchange income is within a reasonable error range from the amount on the customs declaration form.For EXW orders settled in RMB,the bank receipt issued by the bank must be provided with the corresponding export customs declaration number noted,for the tax authority to verify the authenticity of the capital flow.

Prevent "Three-Document Matching" Risks Under Golden Tax Phase IV

In 2026,the tax authority’s review of export tax refund has shifted from "formal review" to "substantive penetration".In EXW tax refund operations,enterprises must strictly guard against the following three high-risk minefields,which are also the key areas inspected by Zhongshitong’s risk control team:

1.Logical risk of HS code classification. Some enterprises deliberately declare complex products as simple part codes to match high tax refund rates.The customs document review center has now introduced an AI-assisted inspection system.Although EXW goods are carried by the buyer,once they are selected for inspection at major ports such as Shanghai and the actual goods are found inconsistent with the declaration,not only will the tax refund be cancelled,but the enterprise will also face fines and downgrade penalties.Zhongshitong has pre-classification qualification,and will conduct strict compliance pre-review of products before declaration.

2.Doubt risk of freight allocation. EXW is theoretically ex-factory price,excluding freight.However,in actual operation,if the seller deliberately overstates the goods value to cover the freight for tax refund,it is very easy to trigger the tax authority’s "price query".The correct approach is: declare the FOB price (i.e.EXW goods value) truthfully,and note in the remark column that the freight is borne by the buyer,to maintain the transparency of financial data.

3.Chain risk of supplier invoices. If the factory is a foreign trade company,the product name on the purchase invoice must be completely consistent with the product name on the export customs declaration form.Many EXW orders involve factory assembly,and there is a product name difference between component invoices and finished product export declaration forms,which is a fatal flaw in 2026 tax letter investigations.Zhongshitong recommends enterprises to sort out input invoices in advance,and for non-self-produced products,must ensure that the product name logic of the procurement chain is self-consistent.

Summary

EXW terms never mean waiving export tax refund.In the low-margin foreign trade environment of 2026,every tax refund is the net profit of the enterprise.With the intervention of Zhongshitong’s professional agency and restructuring the cooperation relationship between customs declaration and logistics,enterprises can fully meet the buyer’s EXW logistics requirements while legally and compliantly obtaining the tax refund.The key is to abandon the fluke mindset,and use professional document operation to hedge against strict regulatory risks.