代理輸出Who bears the tax payment obligation under the model?

Pursuant to the Provisional Regulations on Value-Added Tax and the latest 2025 revision輸出稅還付Administrative Measures, in the export agency business:

• As the actual owner of the goods, the manufacturing enterprise bears the VAT liability.
• Foreign trade agency enterprises are required to fulfill the obligation of withholding and remitting taxes.
  • Required on the goods通関Complete the tax filing within 30 days after export.
  • The complete export contract, customs declaration, and transport documents must be preserved.
• Special Circumstance Handling:
  • Cross-border e-commerce operations must separately declare the 9810 regulatory code.
  • Processing trade must be accompanied by the manual verification and cancellation certificate.

輸出稅還付How can tax payments be balanced with cash flow?

to be implemented in 2025Tax-Treasury Linkage SystemFully electronic processing has been implemented; the specific operational workflow is as follows:

• Step 1: The manufacturing enterprise completes the exemption, credit, and refund declaration.
  • A list of input VAT invoice certifications must be provided (blockchain-based evidence storage supported starting in 2025).
  • The deadline for document filing has been shortened to 90 days.
• Step 2: The agency enterprise files for export tax rebates
  • The customs declaration must exactly match the product name on the VAT invoice.
  • The deadline for foreign exchange collection and verification is extended to the April filing period of the following year.
• Step 3: The tax system automatically offsets the tax amount
  • The export tax rebate amount is directly offset against the enterprise's tax payable.
  • The refund processing period has been shortened to 5 business days.

What are the common risks associated with tax payment in export agency arrangements?

According to the 2023 Customs Audit Case Repository data, the main risks are concentrated in:

• Risk of document mismatch
  • In 2025, Customs will introduce an intelligent HS code verification feature.
  • A discrepancy of more than 5% between the declared customs value and the invoice amount will trigger an alert.
• Timeliness risk
  • Starting in 2024, failure to file for a tax refund within the prescribed period will be treated as domestic sales and subject to supplementary tax.
  • Overdue foreign-exchange verification will result in a 3-percentage-point reduction in the tax rebate rate.
• Agency Qualification Risk
  • It is necessary to verify the AEO certification status of the agency enterprise.
  • Mandatory purchase of tax liability insurance starting in 2025

What to Watch Out for in Paperless Filing in 2025?

Pursuant to State Taxation Administration Announcement No. 2025-6, enterprises must pay special attention to:

• Electronic seal upgraded to the national cryptographic algorithm
• The customs declaration must be linked to blockchain traceability information.
• Input invoices must be encrypted using the Tax Ukey.
• The declaration system automatically validates logistics tracking data

How to guard against tax risks in export agency arrangements?

It is recommended to establishTriple-check mechanism：

• Pre-check
  • Verify the export tax rebate qualification of the agency enterprise
  • Verify the pre-entry information on the customs declaration form
• In-process monitoring
  • Track the progress of foreign exchange receipts
  • Compare the input and output VAT data
• Post-audit
  • Retain the complete set of documents for at least 10 years.
  • Conduct regular end-to-end walkthrough tests of tax refund data