一、代理輸出Who’s the real one in mode通関Reporting entity?

According to the latest 2025 Regulations on the Administration of Customs Declarations for Import and Export Goods, agency export operations must comply with「ダブルヘッダー申告」原則：

• 通関申告書の「國內出荷人」欄には、対外貿易代理企業を記入してください。
• 「生産販売単位」欄には、実際の依頼主の情報を記入してください。
• Special Circumstance Handling:
  • When the commissioning party holds import and export rights, it may choose the declaration method on its own.
  • Cross-border supply chain services must specify the actual owner of the goods.

II. The commissioning party must file the declaration on its own.輸出稅還付?

Announcement No. 38 of 2025 by the State Taxation Administration stipulates:

• The entity responsible for filing the tax refund claim depends onVAT Invoice Flow：
  • The principal issues the invoice to the agency: the agency files for the tax refund.
  • Factory-direct agency enterprise: The principal is not allowed to apply for tax rebates.
• Typical case: A lighting company failed to claim its export tax rebate—losing the full 13 % refund—because the invoice was re-issued across calendar years.

III. How does the transaction term on the customs declaration affect the rights and interests of the principal?

2025 Customs Declaration Form Filling Standards Requirements:

• The choice between FOB and CIF terms directly affects:
  • Eligibility for VAT Deduction on Ocean Freight
  • Subject of transportation insurance claims
  • Foreign Exchange Verification Document Types
• It is recommended that the principal explicitly stipulate the trade terms in the agency agreement.

4. How can the commissioning party ensure compliance in receiving foreign exchange?

According to the new 2025 cross-border receipt and payment regulations issued by the State Administration of Foreign Exchange:

• The remittance received by the commissioning party must meet「三単一致」の原則：
  • The deviation between the customs declaration amount and the foreign exchange receipt amount shall be ≤5%.
  • The currency of receipt matches the currency stipulated in the contract
  • Payer information matches that of the overseas buyer
• Special Handling: Third-party foreign exchange payments must be pre-filed with the "Explanation of Receipt of Foreign Exchange under Special Circumstances".

V. What are the latest precautions for export invoices issued by agents?

New VAT Management Requirements for 2025:

• The invoice issued by the commissioning party must specify代理輸出wordmark
• Required elements in the invoice remarks field:
  • Export Declaration Number (12 digits)
  • Payment method (TT/LC, etc.)
  • Exchange Rate Applicable Date
• Error Case: A chemical company was ordered to repay its input VAT due to missing exchange-rate information.

六、「偽りの自営?実質的代理」のリスクをどう防ぐか？

Key priorities for the 2025 Customs General Administration’s special audit include:

• Four categories of high-risk scenarios:
  • The entrusted party's account directly receives and pays foreign exchange.
  • Abnormal agency fee payment ratio (normally 0.8–1.5%)
  • The logistics documents show the actual shipper's information.
  • Price discrepancies for the same product across multiple customs declarations exceed 30%
• Compliance Recommendation: Establish a completeAgent Export Business Ledger

7. What application materials must the commissioning party retain?

It is recommended to retain core documents for at least five years:

• Original Copy of the Export Agency Agreement
• Copy of the customs declaration (stamped with the agent’s official seal)
• Foreign Exchange Receipt
• Proof of Delivery
• 2025 New Requirement: Blockchain-Based Electronic Verification Report

VIII.RCEPCan the certificate of origin be applied for by the commissioning party?

According to the 2025 RCEP Implementation Rules:

• Eligibility Determination for Filing Entity:
  • The commissioning party holds production qualifications and may apply on its own.
  • The trading company is required to provideProof of Industry Chain
• Special Notice: ASEAN member states have introduced new evidentiary requirements for origin certification applications.