Core Conditions and Practical Steps for Trade Companies Applying for Export Tax Refunds

Can Trade Companies Enjoy Export Tax Refunds?2026 Latest Judgment Standards

Many trade companies will struggle with the core question of "whether they can enjoy export tax refunds" when expanding into overseas markets.The latest policies of the General Administration of Customs and the State Taxation Administration in 2026 clearly stipulate that eligible trade companies (foreign trade circulation enterprises) can apply for export tax refunds normally,and not only manufacturing enterprises are eligible for this policy.

Core Judgment Criteria (2026 Edition)

The requirements of the 2026 export tax refund policy for trade companies have been further simplified,but they still need to meet the following 5 mandatory standards:

• The enterprise holds the qualification of general VAT taxpayer; small-scale taxpayers can only enjoy export tax exemption and cannot apply for tax refunds
• Export goods have actually been declared and departed from the territory,and complete electronic customs declaration data can be queried through the Single Window for International Trade of China
• Foreign exchange has been collected in accordance with regulations (in 2026,some pilot areas allow a 90-day extension for foreign exchange collection,and a reasonable extension explanation needs to be submitted)
• Export goods fall within the VAT levy scope,and the enterprise has paid VAT for the corresponding links in accordance with regulations
• Possess legal and valid purchase certificates,namely special VAT invoices (electronic invoices have been included in the compliance scope)

It should be noted that the restriction that "export goods of trade companies must be self-produced" has been canceled in 2026.As long as the goods are compliant and documents are complete,circulation goods can also apply for tax refunds.

Common Misconceptions About Tax Refunds for Trade Companies in 2026

Among nearly 1,000 trade companies we served at the Shanghai port,more than 60% have fallen into tax refund misconceptions,and the 3 most typical ones are as follows:

• Misconception 1: Trade companies must export self-produced goods to get tax refunds — this requirement was canceled in 2025 and the adjustment is continued in the 2026 policy
• Misconception 2: Trade companies without import and export rights cannot apply for tax refunds — they can entrust professional foreign trade agencies to handle tax refund declarations
• Misconception 3: Small-scale taxpayers can apply for export tax refunds — they can only enjoy export tax exemption and cannot deduct input VAT and obtain tax refunds

We have served a hardware trade company in Shanghai.In 2025,it gave up tax refund funds of 120,000 yuan because it mistakenly thought it needed to export self-produced goods to get tax refunds.Later,we assisted it in completing documents,and it successfully received all tax refund funds 3 months later.

Practical Process for Trade Companies’ Export Tax Refunds (2026 Fully Electronic Edition)

In 2026,the General Administration of Customs fully implemented electronic declaration through the Single Window,paper documents are no longer required to be submitted,and the practical process has been greatly simplified:

1.Pre-filing Preparation

Complete the change of business scope (adding "import and export of goods"),filing of import and export rights,filing of general VAT taxpayer qualification,and filing of export tax refund (exemption).

2.Document Collection and Review

Collect export contracts,special VAT invoices for purchases,electronic customs declaration data,and foreign exchange collection vouchers.In 2026,customs declaration data can be synchronized with one click through the Single Window without manual entry.

3.Tax Refund Declaration and Review

Submit tax refund declarations through the Single Window for International Trade of China.The tax authorities will complete the review within 15 working days (compressed to 7 working days in pilot areas in 2026).The tax refund funds will be transferred to the enterprise’s corporate account after approval.

2026 Export Tax Refund Policy Change Comparison Table

Risk Warning and Pitfall Avoidance Guide for Trade Companies’ Tax Refunds

The Shanghai Port Customs’ control inspection rate in 2026 has increased by 12% compared with 2025,so trade companies need to focus on avoiding the following 4 types of risks:

• HS Code Classification Error: For example,classifying hardware tools as ordinary goods leading to mismatched tax refund rates and even being identified as tax fraud; we can provide pre-classification services to avoid this risk in advance
• Abnormal Purchase Invoices: Issues such as false special VAT invoices or the invoice issuer being missing will lead to the rejection of tax refunds and even face tax inspections
• Foreign Exchange Collection Inconsistency: The amount of foreign exchange collected is inconsistent with the amount on the customs declaration; a reasonable explanation is required,otherwise the tax refund review will not pass
• Violation of Certificate of Origin Rules: Goods from RCEP member countries that fail to apply for FORM R certificates correctly cannot enjoy tax refund rate preferences and may even be subject to high tariffs

We have served a chemical trade company in Suzhou.In 2025,due to HS code classification error,it was originally eligible for a 10% tax refund rate but was finally classified as 3%,losing tax refund funds of 280,000 yuan.Later,we assisted it in reclassifying and completing the appeal,successfully recovering all losses.

Core Value of Professional Agency Services

For trade companies without dedicated foreign trade finance and tax staff,entrusting professional agencies can save more than 30% of document processing time and reduce compliance risks.As a foreign trade service institution rooted in Shanghai,Zhongshitong can provide the following one-stop services:

• Filing of import and export rights and filing of export tax refund (exemption)
• Pre-classification of HS codes and review of declaration elements
• Document sorting and electronic tax refund declaration
• Foreign exchange collection verification and tax refund progress follow-up
• Export tax refund planning and risk investigation

The global trade environment in 2026 is complex.Export tax refunds are an important source of stable profits for trade companies,but compliance requirements are becoming increasingly strict.Enterprises need to understand the policies in advance to avoid pitfalls.