AgencyAgency export,Must the invoice be issued by the client?

In accordance with the "Notice of the Ministry of Finance and the State Taxation Administration on Value-Added Tax and Consumption Tax Policies for Export Goods and Services" (2023 Revised Edition),For entrusted agency exports, the entrusting party must issue a general VAT invoice.. The specific operational procedure is as follows:

• The entrusting party (manufacturer/foreign trade company) issues a value-added tax ordinary invoice to the entrusted party (agent company) at a tax rate of 0%.
• The remarks section of the invoice must indicate the phrase "agency export" and the correspondingcustoms clearanceTracking number
• The entrusted party shall handle the matter based on the invoice provided by the entrusting party.Export tax refunddeclare

2. What is the difference between invoicing for export through an agent and self-operated export?

Under the current policies in 2025, the differences between the two models of invoices are mainly reflected in:

• The invoicing entities are different:
  • Self-operated export: The exporting enterprise issues the value-added tax special invoice independently.
  • Agency export: The principal issues a general VAT invoice.
• Tax refund declaration method:
  • Self-operated export: The exporting enterprise directly declares tax refunds.
  • Agency export: Declared by the entrusted party, requiring submission of the "Certificate of Agency Export Goods."

III. What are the common errors in agency export invoices?

According to the 2024 audit cases from the General Administration of Customs, common errors include:

• Incorrect issuance of a 13% tax rate invoice (should maintain a 0% tax rate).
• Missing key remarks such as the customs declaration number.
• The invoice issuance date is more than 60 days later than the customs export declaration date.
• The "Agency Export Agreement" filing has not been submitted for synchronization.

A textile company in 2023 experienced a delay of 6 months in receiving a tax refund of 2.87 million yuan due to missing customs declaration numbers in the invoice remarks column, resulting in additional financing costs of approximately 120,000 yuan.

IV. What documents are required for the 2025 tax refund application?

The current list of required submission materials includes:

• Original copy of the VAT ordinary invoice issued by the entrusting party.
• Customs-verifiedExport customs clearanceOrder
• The "Certificate of Agency Export Goods" signed and sealed by both parties.
• Foreign Exchange Receipt Verification Certificate (Deadline for Receipt Extended to April 30 of the Following Year)

V. How to handle invoices for special trade methods?

For emerging business models such as cross-border e-commerce, special attention should be paid to:

• Market Procurement Trade:Applicable to Regulation Code 1039, the entrusting party shall issue a tax-exempt ordinary invoice.
• Overseas warehouse model:The invoice remarks section must indicate "Overseas Warehouse" and the warehouse country code.
• Returned Goods:The original invoice must be reversed (red-stamped) and accompanied by the Customs' "Certificate of Tax Refund for Returned Goods (Tax Not Refunded)."

It is recommended that enterprises, when engaging in entrusted agency export business,Confirm the invoice elements template with the agency in advance.Establish a bill review mechanism. For special trade methods, taxpayers may apply to the competent tax authority for an Advance Pricing Arrangement (APA) to reduce compliance risks.