一、輸出代理店Is service charge subject to value-added tax?

Pursuant to the latest revision in December 2024 of the Ministry of Finance’s “Administrative Measures for Value-Added Tax on Cross-Border Taxable Activities,” export agency service fees are subject toZero-tax-rate policy, but three core conditions must be met:

• The service recipient is an overseas entity or individual
• Agency services are directly related to the export of goods
• Enterprises must retain complete通関invoices, transport documents, and other supporting materials

Special Reminder: If the agency also provides additional services such as domestic warehousing, the revenue from this portion must be6%Pay value-added tax. In 2024, a cross-border e-commerce company overpaid taxes by 120,000 yuan due to the failure to properly separate its mixed operations; it is recommended that the company establish a detailed service-item ledger.

II. Can agency fees be deducted as input VAT?

The input VAT on fees paid by export enterprises to agency companies must be handled separately:

• Deductible portion：
  • International freight forwarding fee (a special VAT invoice must be obtained)
  • Customs Declaration and Inspection Service Fee (subject to 6% tax rate)
• Non-deductible portion：
  • International segment logistics costs
  • Foreign Trade Consulting Service Fee

Calculation example: In 2024, a company pays an agency fee of 500,000 RMB (tax-inclusive), of which 60% is deductible. The deductible input VAT = 500,000 × 60% ÷ (1 + 6%) × 6% ≈ 16,981 RMB

三、輸出稅還付What is the connection with the agency fee?

Agency fees directly affect輸出稅還付the two key links:

• Calculation of Tax Refund: International freight charges must be deducted from the FOB price
• Document Management: Missing an agency agreement may lead to delays in tax refunds

2024 Typical Case: An electromechanical export company was audited for over-claiming a tax refund of RMB 230,000 because it failed to exclude freight forwarding charges from the FOB price. Companies are advised to establishCost Allocation Calculation Sheet, clearly distinguish between the price components of CIF and FOB.

四、クロスボーダー決済Is income tax required to be withheld from the agency fee?

According to the latest interpretation of the Implementation Regulations of the Enterprise Income Tax Law:

• Payment of overseas agency service fees is subject to withholding tax.6% VATand10% corporate income tax
• If the other party's country has signed a tax treaty with China, preferential tax rates may apply.

Risk Alert: A 2024 special inspection by the tax authority of a certain province found that 37% of foreign trade enterprises had errors in their cross-border payment tax treatment. It is recommended to explicitly stipulate tax and fee bearing clauses in the contract and conduct advanceFiling for Tax Treaty Benefits」でした.

V. How can the tax burden related to agency fees be legally reduced?

Based on the 2024–2025 tax policies, three optimization pathways are recommended:

• Business Model Reengineering: Transition part of the agency services into supply chain management services
• Tax Incentive Eligibility: Qualified comprehensive foreign trade service enterprises may enjoy an additional input VAT deduction.
• Reasonable cost allocation: Distinguish core proxy services from value-added services

Through program optimization, a certain apparel-export enterprise achieved a 2024 tax-saving effect equivalent to 0.8% of its operating revenue. However, care must be taken to avoid touchingTransfer pricingRegulatory red line: professional tax planning is recommended.

(Note: The policies described in this article are valid as of March 2025. For specific transactions, please refer to the determination of the competent tax authority. For complex transactions, it is recommended to consult a professional tax advisor for case-by-case analysis.)