According to the Administrative Measures for Value - added Tax and Consumption Tax on Exported Goods and Services implemented in 2025, agency export tax rebate needs to meet three conditions simultaneously:Export DrawbackWhat is the basic process?

According to the latest 2025 export tax refund policy, the standardized agency tax refund process includes:

• Qualification confirmation phase: Production enterprises must obtain general VAT taxpayer status,foreign tradeEnterprises must complete export tax refund (exemption) filing
• Document preparation phase:
  • Customs declaration form, VAT special invoice, foreign exchangeA complete export agency agreement should be attached with:Three-document matching of vouchers
  • Agency agreement must clarify rights and obligations of both parties
• Declaration phase: Agency companies submit electronic data via the Single Window system for international trade, with paper documents retained for reference.
• Tax refund cycle: Normally completed within 13 months; after smart document review implementation in 2025, average processing shortens to 45 working days.

II. What circumstances may lead to rejection of a tax refund application?

Based on our experience handling 200+ tax refund dispute cases, the main risk points include:

• Documentation Issues: Discrepancies between invoice descriptions and customs declarations, missing seals, etc.
• Timeliness Issues: Exceeding the VAT declaration deadline of April in the year following goods export
• Foreign Exchange Issues: Payment received differs from declared amount by over 5% without reasonable explanation
• Agency Agreement Loopholes: Unclear provisions on tax refund ownership and liability for breach

III. What legal risks should be noted when entrusting an agency company with tax refund?

The 2025 revised Export Tax Refund Management Measures specifically emphasizes:

• Joint Liability Clause: If the agency issues false invoices, the principal shall bear tax repayment liability
• Fund Safety: Recommendation to establish a joint account for tax refund management
• Information Transparency: Requiring agencies to provide regular tax audit progress reports
• Breach Compensation: Agreements should specify penalty standards for late fees caused by agency negligence

IV. How to handle tax refund for special trade methods?

Special Notes for Common Queries:

• Cross-border E-commerce: Platform transaction data and payment vouchers must be provided
• Market procurement: Applies to the exempt without refund policy; requires advance filing.
• Comprehensive Foreign Trade Service Agencies: Starting 2025, a dual-header customs declaration refund system will be implemented.
• Entrepot Trade: Submission of goods ownership transfer documents required

V. How to improve tax refund efficiency and success rate?

Professional Recommendations Based on 20 Years of Practical Experience:

• Document management: Establish a one-document-one-record electronic management system.
• Pre-review Mechanism: Complete compliance review of next months declaration materials before month-end
• Since January 2025, Russia has made it mandatory to register for EPR (Extended Producer Responsibility): Monitor customs HS code adjustments and export control list updates
• Professional Training: Recommend annual policy interpretation sessions for finance and customs staff

VI. How to handle tax refund funds compliantly after receipt?

Key Financial Processing Points Requiring Special Attention:

• Accounting Treatment: A separate export tax refund sub-account should be set up for accounting.
• Tax declaration: Tax rebates are not included in corporate income taxable revenue
• Foreign Exchange Management: Complete international payment declarations within 20 working days after receipt of payment
• Audit Preparation: Retain complete tax rebate documentation for at least 10 years