In a Pure Export Agency Business, Who Exactly Handles the Tax Refund?

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My company plans to find an agent for export business, using a pure agency model. However, I'm not very clear about the tax refund aspect. I'd like to know whether it's the entrusting party or the agency party that handles the tax refund in a pure export agency business. Will the tax refund process be very complicated? What documents need to be prepared? I hope for a detailed answer so we can prepare in advance.
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In a pure export agency business, generally the entrusting party handles the tax refund. This is because the entrusting party is the actual seller of the goods, and the refund of related taxes such as VAT and consumption tax on exported goods should belong to the entrusting party.

The main responsibility of the agency party is to assist the entrusting party with export-related procedures, including customs declaration and inspection, but it does not directly participate in the tax refund.

The general process for the entrusting party to claim a tax refund is as follows: First, complete the export of goods and obtain relevant documents such as customs declarations. Then, organize these documents and other required materials. Apply for a tax refund to the competent tax authority within the stipulated declaration period. Required documents typically include export goods customs declarations, export invoices, agency export goods certificates (provided by the agency party), VAT special invoices, etc. As long as the documents are complete and procedures comply with regulations, although the tax refund process has a certain complexity, it can be processed step by step according to regulations.

References: Wenzhou Export Agency Tax Rebate: Do You Really Understand It?

Indeed, it is the entrusting party that claims the tax refund. However, the agency party also plays a crucial supporting role, such as promptly and accurately providing necessary documents and assisting the entrusting party in completing preparatory work before the tax refund application.

When the entrusting party claims a tax refund, attention must be paid to the declaration time limit. Generally, it is before the deadline of the VAT tax declaration period in April of the year following the export date; otherwise, it may affect the tax refund.

The agency party cannot claim a tax refund. However, it must issue an agency export goods certificate to the entrusting party as per regulations, which is one of the important vouchers for the entrusting party's tax refund.

When the entrusting party claims a tax refund, it must strictly review the VAT special invoices and other documents obtained to ensure their authenticity and compliance. Otherwise, the tax refund will be hindered.

For pure export agency tax refunds, the entrusting party also needs to pay attention to the foreign exchange collection status of the goods. In some cases, foreign exchange collection is a necessary condition for the tax refund.

If the entrusting party is a foreign trade enterprise, the tax refund calculation is relatively simple, calculated based on the amount indicated on the VAT special invoices for purchased goods; if it is a manufacturing enterprise, the calculation will be more complex.

During the entrusting party's tax refund process, if policy changes or special circumstances are encountered, it should communicate with the tax authorities promptly to avoid problems with the tax refund.

The agency party must operate in a standardized manner throughout the export process. If the entrusting party suffers tax refund losses due to the agency party's errors, the agency party may be held responsible.

When the entrusting party prepares tax refund documents, they should be categorized, organized, and bound according to the requirements of the tax authorities to facilitate review and improve tax refund efficiency.

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