Tax Refund Upon Departure! The State Administration Of Taxation Issued A Document To Support The Development Of Cross-Border E-Commerce Export Overseas Warehouses

Announcement on Supporting the Development of Export Tax Refund (Exemption) for Overseas Warehouse of Cross border E-Commerce

Announcement No. 3, 2025 of the State Administration of Taxation 　　

　　 In order to thoroughly implement the decisions and arrangements of the CPC Central Committee and the State Council, and support the development of new business types and new models such as cross-border e-commerce export overseas warehouses, the State Administration of Taxation has decided to implement "tax refund upon departure" for goods exported by taxpayers in the form of cross-border e-commerce export overseas warehouses (hereinafter referred to as export overseas warehouses). The matters concerning export tax rebate (exemption) are hereby announced as follows:

　　 1、 Taxpayers who export goods in the form of export overseas warehouse (customs supervision code "9810", the same below) can apply for export tax refund (exemption) after the goods are declared to leave the country. When taxpayers apply for export tax rebate (exemption), if the goods have been sold, they shall apply for export tax rebate (exemption) in accordance with the current regulations; If the goods have not yet been sold, the export tax rebate (exemption) shall be declared and handled according to the method of "tax rebate upon departure and sales re accounting", that is, after the goods are declared for departure, the export tax rebate (exemption) can be declared and handled in advance (hereinafter referred to as export tax rebate), and then the tax accounting shall be carried out according to the sales of goods.

　　 2、 Taxpayers shall, on the strength of the export goods declaration form and relevant material information, report to the competent tax authorities for handling export pre refund, and shall also report in accordance with the following requirements:

　　 （1） Fill in the "Tax Refund (Exemption) Business Type" column in the declaration details with the "Overseas Warehouse Pre refund" identification (business type code: HWC-YT）。

　　 （2） Distinguish between the goods that have not been sold and the goods that have been sold, and declare the export tax refund in advance and the export tax refund (exemption) respectively; If no distinction is made, it shall be deemed that the goods have not been sold, and the declaration of export tax advance refund shall be made uniformly.

　　 If all the goods under the same item number on the export goods declaration form have not been sold, the taxpayer can make a differentiated declaration according to the provisions of the preceding paragraph, or regard all the goods under this item number as not sold, and make a unified declaration of export tax advance rebate.

　　 （3） The production enterprise shall use a separate declaration serial number, and the foreign trade enterprise shall use a separate association number to declare the export pre rebate.

　　 3、 Taxpayers who have applied for handling export pre refund shall handle the accounting of export pre refund within each VAT tax declaration period before the end of the accounting period. With the consent of the competent tax authority, foreign trade enterprises can also handle the accounting of export pre refund tax at other times beyond the VAT declaration period before the deadline of the accounting period. The above accounting period refers to the period from the first day of the next month to April 30 of the next year when the tax authority completes the export pre rebate.

　　 If a taxpayer fails to handle the accounting before the deadline of the accounting period, the tax authority shall recover the export pre refund already handled; After the goods are sold, the taxpayer will apply for export tax refund (exemption) in accordance with the current regulations.

　　 4、 When a taxpayer handles the accounting of export pre refund tax, it shall, according to the actual sales situation, distinguish between the following different situations:

　　 （1） If the goods have been sold at the time of accounting, the difference between the refundable (exempted) tax calculated according to the actual sales situation and the pre refundable export tax shall be recognized. If there is no difference, the taxpayer shall confirm that "no adjustment of declaration is required" and go through the tuberculosis settlement procedures; In case of any discrepancy, the taxpayer shall go through the tuberculosis accounting procedures after confirming that "the declaration needs to be adjusted" and making the adjusted declaration.

　　 （2） If the goods have not yet been sold at the time of accounting, the taxpayer shall go through the procedures of tuberculosis accounting after confirming that "the declaration needs to be adjusted" and paying back the export tax rebate in full. Later, after the sales of the goods are realized, the taxpayer can re apply for export tax refund (exemption) in accordance with the current regulations.

　　 The specific operation mode of the above adjustment declaration and return of export pre refund tax is: when taxpayers apply for export tax refund (exemption) in the current accounting period, they should first offset the declaration data of export pre refund tax in the previous period with a negative amount in full, and then re apply for export tax refund (exemption) according to the actual sales of goods and the current regulations. In the current accounting period, if the amount of tax refundable (exempted) by the taxpayer is negative, the production enterprise shall carry forward to the next period for further deduction, and the foreign trade enterprise shall make up the tax; If the amount of tax to be refunded (exempted) is positive, the tax authorities shall handle export tax refund (exemption) in accordance with the current regulations.

　　 5、 If a taxpayer who has applied for handling export tax rebate in advance but has not yet handled accounting needs to change the tax rebate (exemption) method and withdraw the record of export tax rebate (exemption), it shall first handle the accounting of export tax rebate. After they have gone through the tuberculosis accounting procedures and settled the export tax rebate (exemption), the tax authorities will go through the procedures in accordance with the current regulations.

　　 6、 If a taxpayer exports goods by exporting overseas warehouses, in addition to the requirements of the current regulations on the management of export tax refund (exemption) filing documents, the following provisions shall also be followed:

　　 （1） If the export contract cannot be obtained, the taxpayer can choose to use the overseas warehouse order, proprietary documents of the self operated overseas warehouse, lease agreement of the overseas warehouse or other relevant materials that can support the use of the overseas warehouse for document filing.

　　 （2） Taxpayers shall use sales accounting vouchers, sales sub ledgers and other materials that can prove that the goods have been sold (hereinafter referred to as sales supporting materials) as export tax refund (exemption) filing documents. If a taxpayer applies for handling export pre refund of tax, it shall complete the retention of sales supporting documents within 15 days after the goods are sold for verification by the tax authority; For those who apply for export tax refund (exemption) according to the current regulations, they shall complete the retention of sales supporting documents for the tax authorities' verification within 15 days after applying for export tax refund (exemption).

　　 Taxpayers can choose paper-based, image-based or digital methods to retain and keep the above-mentioned filing documents.

　　 7、 Taxpayers shall truthfully declare and handle export pre refund and accounting according to law. The tax authorities shall, in accordance with the current provisions, examine and verify the handling of export pre refund and accounting. If there is any doubt about defrauding export tax refund, the tax authorities shall check and eliminate the doubt before handling it. When carrying out the verification, the tax authority shall also check the actual sales situation. If it is found that the sales supporting materials are not retained as required or are forged or false, the tax refunded (exempted) shall be recovered and handled according to the current regulations; If it is verified that the export tax rebate is defrauded, it shall be handled in accordance with the Law of the People's Republic of China on the Administration of Tax Collection and relevant regulations.

　　 8、 Matters not covered in this announcement shall be implemented in accordance with the current provisions on export tax rebate (exemption).

　　 9、 This announcement shall come into force as of the date of promulgation. Before the implementation of this Proclamation, if taxpayers export goods by means of export overseas warehouses, but have not yet declared export tax rebate (exemption), the provisions of this Proclamation shall apply.

　　 It is hereby announced.

　　 State Administration of Taxation

　　 January 27, 2025 　　

　　 Interpretation:

Interpretation of the Announcement of the State Administration of Taxation on Supporting the Development of Export Tax Rebates (Exemptions) for Overseas Warehouse of Cross border E-Commerce Exports 　　 　　

　　 In order to better play the positive role of export tax rebate in supporting the development of cross-border e-commerce export overseas warehouses (hereinafter referred to as export overseas warehouses), the State Administration of Taxation has issued the Announcement of the State Administration of Taxation on Matters Related to Export Tax Rebate (Exemption) in Supporting the Development of Cross border E-commerce Export Overseas Warehouse (hereinafter referred to as the Announcement), Clarify the matters related to tax refund (exemption) for export of goods exported by taxpayers in the form of export overseas warehouse (customs supervision code "9810", the same below). The relevant contents are interpreted as follows: 　　 　　

　　 1、 How should taxpayers apply for export tax refund (exemption) when exporting goods in the form of export overseas warehouses? 　　 　　

　　 Taxpayers who export goods in the form of export overseas warehouses can apply for export tax refund (exemption) based on the export goods declaration form and other relevant materials after the goods are declared to leave the country. In the specific operation, the taxpayer shall determine the specific declaration method according to the sales of goods: when declaring export tax rebate (exemption), if the goods have been sold, the taxpayer shall declare and handle export tax rebate (exemption) according to the current regulations; If the goods have not yet been sold, the export tax rebate (exemption) shall be declared and handled according to the method of "tax rebate upon departure and sales re accounting", that is, the export tax rebate (exemption) shall be declared and handled in advance (hereinafter referred to as export tax rebate) based on the material information such as the export goods declaration form, and then the tax accounting shall be carried out according to the sales of goods. 　　 　　

　　 2、 How should taxpayers declare and handle export pre refund? 　　 　　

　　 Taxpayers shall apply to the tax authorities for handling export pre refund of taxes by presenting the customs declaration form of export goods and other relevant materials and information with the customs supervision code of "9810". Attention should be paid to: First, when filling in the declaration details, the "overseas warehouse pre refund" sign should be filled in the "tax refund (exemption) business type" column, and the business type code is: HWC-YT。 The second is to distinguish the goods that have not been sold from the goods that have been sold, and declare the export tax rebate and export tax rebate (exemption) respectively; If no distinction is made, all of them shall be deemed as unrealized sales, and the export tax advance rebate shall be uniformly declared. Third, if the taxpayer is a production enterprise, it shall use a separate declaration serial number to declare the export pre rebate; If the taxpayer is a foreign trade enterprise, it shall use a separate association number to declare the export pre refund tax. 　　 　　

　　 3、 When the goods under the same item number on the export goods declaration form are not all sold, how should the taxpayer declare and handle the export tax advance refund? 　　 　　

　　 For the goods under the same item number on the export goods declaration form, the taxpayer can distinguish the part that has been sold from the part that has not been sold, and the part that has been sold will be declared for export tax refund (exemption) in accordance with the current regulations; For the part that has not been sold, it is required to apply for handling export tax advance rebate. If the taxpayer does not make a distinction, all of them can be regarded as not being sold, and it is required to apply for export pre refund in a unified way. 　　

　　 For example: 　　

　　 A production enterprise declared 100 tea cups for export through the same item number in the same export goods declaration form. The export date indicated on the export goods declaration form issued by the customs is February 25, 2025. The enterprise plans to apply for export tax refund (exemption) on this goods on March 10, 2025.

　　 Scenario 1: On March 10, 2025, 20 of the 100 tea cups exported by the enterprise have been sold, and the remaining 80 have not yet been sold. When the enterprise applied for export tax refund (exemption) on March 10, it applied for tax exemption, credit and refund for 20 tea cups that had been sold according to the current regulations; For 80 tea cups that have not been sold, the export tax advance refund shall be declared and handled according to the method of "tax refund upon departure and sales re accounting". When filling in the declaration list, the enterprise should pay attention to: First, when handling the declaration of export pre refund of 80 unsold tea cups, it should fill in the "HWC-YT" logo in the "Tax refund (exemption) business type" column of the declaration list. The second is to use different declaration serial numbers for 20 tea cups that have been sold and 80 tea cups that have not been sold.

　　 Case 2: When the enterprise applied for export tax rebate (exemption) on March 10, it did not distinguish which of the 100 tea cups exported had been sold and which had not been sold. At this time, the enterprise can apply for export tax rebate for 100 tea cups in accordance with the method of "tax rebate upon departure, sales re accounting". When declaring, the enterprise shall fill in the "HWC-YT" logo in the "Tax Refund (Exemption) Business Type" column of the declaration list, and use the same declaration serial number for the above 100 cups.

　　 4、 When should a taxpayer go through accounting if it has applied for handling export pre refund?

　　 If a taxpayer has declared for handling export pre refund, it shall handle accounting within each VAT declaration period before the end of the accounting period. The above accounting period refers specifically to the period from the first day of the next month to April 30 of the next year when the tax authorities complete the export pre rebate. In actual operation, taxpayers can handle the accounting in any VAT declaration period within the accounting period, but no later than the deadline of the VAT declaration period in April of the next year when the tax authorities complete the export pre rebate. With the consent of the tax authority, a foreign trade enterprise may conduct accounting at any time during the accounting period, and is not subject to the limitation of the VAT declaration period.

　　 For example:

　　 Scenario 1: A production enterprise declared export pre rebate on February 10, 2025. The tax authorities shall, in accordance with the current regulations, examine and verify the export pre refund declared by the enterprise. After verification, there is no problem with this business, and the tax authority will complete the export pre rebate for enterprises on February 13, 2025. At this time, the production enterprise can handle accounting within any VAT declaration period from March 2025 to April 2026, but no later than the deadline of the VAT declaration period in April 2026.

　　 Scenario 2: A foreign trade enterprise declared export tax advance rebate on December 31, 2025. The tax authorities shall, in accordance with the current regulations, examine and verify the export pre refund declared by the enterprise. After verification, there is no problem with this business, and the tax authority will complete the export pre rebate for enterprises on January 2, 2026. At this time, the foreign trade enterprise can handle accounting in any VAT declaration period from February 2026 to April 2027, but no later than the deadline of the VAT declaration period in April 2027. With the consent of the tax authority, the enterprise can handle accounting at any time from February 2026 to April 2027, without being restricted by the VAT tax declaration period.

　　 5、 How do taxpayers handle the accounting of export tax advance and refund?

　　 In order to help taxpayers handle accounting accurately and efficiently, the tax authorities push the list of export tax advance and rebate data that have been completed by the tax authorities but not yet accounted for by the taxpayers to the taxpayers through the electronic tax bureau, international trade "single window" and other information systems.

　　 Taxpayers shall, according to the actual sales situation, confirm whether the goods have been sold and whether the export tax advance rebate needs to be adjusted, and deal with them according to the following different situations:

　　 （1） If the goods have been sold and there is no difference between the amount of tax refundable (exempted) for export calculated according to the actual sales situation and the amount of tax refundable in advance for export, the taxpayer shall check and submit the option of "declaration without adjustment" in the information system for confirmation, and then go through the tuberculosis settlement procedures;

　　 （2） If the goods have been sold, but there is a difference between the export tax rebate (exemption) calculated according to the actual sales situation and the export pre refund tax, the taxpayer should check the option of submitting "declaration needs adjustment" in the information system for confirmation, and go through the accounting procedures after the adjustment declaration is made;

　　 （3） If the goods have not been sold yet, the taxpayer shall check the option of "declaration needs to be adjusted" in the information system for confirmation, and go through the tuberculosis settlement procedures after paying back the export tax advance refund in full. After the subsequent sale of the goods, the taxpayer will re apply for export tax refund (exemption) in accordance with the current regulations, and the method of "tax refund upon departure and sales re accounting" will no longer apply.

　　 For example:

　　 For 100 tea cups exported by a manufacturing enterprise in the form of export overseas warehouse, the export pre refund tax will be declared on March 10, 2025, and the export pre refund tax will be 1300 yuan. After verification, there is no problem with this business, and the tax authority will settle the export tax rebate of 1300 yuan for the enterprise on March 14, 2025. The enterprise plans to handle the accounting of export pre rebate on December 12, 2025.

　　 Scenario 1: On December 12, 2025, when the enterprise is accounting, 100 tea cups that have handled export pre rebate have been sold. The export tax rebate (exemption) calculated by the enterprise according to the actual sales situation is 1300 yuan, which is no different from the export pre rebate already handled before. At this time, the taxpayer checks and submits the option of "declaration without adjustment" in the information system for confirmation, and then goes through the tuberculosis settlement procedures.

　　 Scenario 2: On December 12, 2025, 100 tea cups that have handled export tax pre rebate have been sold at the time of enterprise accounting. The export tax rebate (exemption) calculated by the enterprise according to the actual sales situation is 1235 yuan, which is different from the 1300 yuan export pre rebate already handled before. At this time, the taxpayer should check and submit the option of "declaration to be adjusted" in the information system for confirmation and adjustment declaration. When adjusting the declaration, the enterprise shall first submit a declaration data of tax exemption, credit and rebate with the export tax rebate (exemption) of - 1300 yuan, and offset the previously submitted declaration data of export tax advance and rebate in full; Then, according to the actual sales situation, resubmit a tax exemption, credit and refund declaration data with an export tax rebate (exemption) of 1235 yuan. Without considering other influencing factors, the amount of tax refundable (exempted) declared by the enterprise in the current period in December 2025 is - 65 yuan (- 65 yuan=- 1300 yuan+1235 yuan). After being approved by the tax authority, the enterprise shall carry forward the tax rebate (exemption) of - 65 yuan to participate in the calculation of export tax rebate (exemption) in the next period.

　　 Scenario 3: On December 12, 2025, when the enterprise is accounting, 100 tea cups that have handled export pre rebate have been sold. The export tax rebate (exemption) calculated by the enterprise according to the actual sales situation is 1365 yuan, which is different from the 1300 yuan export pre rebate already handled before. At this time, the taxpayer should check and submit the option of "declaration to be adjusted" in the information system for confirmation and adjustment declaration. When adjusting the declaration, the enterprise shall first submit a declaration data of tax exemption, credit and rebate with the export tax rebate (exemption) of - 1300 yuan, and offset the previously submitted declaration data of export tax advance and rebate in full; Then, according to the actual sales situation, resubmit a tax exemption, credit and refund declaration data with an export tax rebate (exemption) of 1365 yuan. Without considering other influencing factors, the amount of tax refundable (exempted) in December 2025 is 65 yuan (65 yuan=- 1300 yuan+1365 yuan). After passing the examination and verification, the tax authority shall handle the export tax rebate (exemption) for the enterprise in accordance with the current provisions of 65 yuan.

　　 Scenario 4: On December 12, 2025, in the accounting of enterprises, 30 of the 100 tea cups that have handled export pre tax rebates have been sold and 70 have not been sold. For the 30 tea cups sold by the enterprise, the export tax rebate (exemption) calculated according to the actual sales situation is 390 yuan, which is different from the 1300 yuan export pre rebate already handled before. At this time, the taxpayer should check and submit the option of "declaration to be adjusted" in the information system for confirmation and adjustment declaration. When adjusting the declaration, the enterprise shall first submit a declaration data of tax exemption, credit and rebate with the export tax rebate (exemption) of - 1300 yuan, and offset the previously submitted declaration data of export tax advance and rebate in full; Then, according to the actual sales situation, resubmit a declaration data of 390 yuan of export tax rebate (exemption). Without considering other influencing factors, the amount of tax refundable (exempted) for the current period in December 2025 is - 910 yuan (- 910 yuan=- 1300 yuan+390 yuan). After being approved by the tax authority, the enterprise shall carry forward the tax rebate (exemption) of - 910 yuan to participate in the calculation of export tax rebate (exemption) in the next period. For 70 tea cups that have not been sold, the enterprise will apply for export tax refund (exemption) according to the current regulations after they have been sold.

　　 6、 What should be done if a taxpayer fails to handle the accounting of export pre refund tax within the prescribed time limit?

　　 If a taxpayer fails to handle the accounting of export pre refund within the prescribed time limit, the tax authorities shall recover the export pre refund already handled; After the goods are sold, the taxpayer will apply for export tax refund (exemption) in accordance with the current regulations.

　　 7、 What filing documents need to be retained for taxpayers to apply for export tax refund (exemption) for goods exported to overseas warehouses?

　　 The export tax refund (exemption) filing documents that taxpayers should keep include:

　　 （1） Purchase and sales contracts of export enterprises (including export contracts, comprehensive service contracts for foreign trade, purchase contracts for foreign trade enterprises, purchase contracts for production enterprises to purchase non self produced goods for export, etc.).

　　 （2） Transport documents of export goods (including: shipping bills of lading, air waybills, railway waybills, cargo transport documents, postal receipts and other cargo documents issued by the carrier, domestic transport invoices of export enterprises to pay freight, invoices of international freight agency services of export enterprises to pay fees, etc.).

　　 （3） Documents for customs declaration entrusted by the export enterprise to other units (including: entrusted customs declaration agreement, invoice for agency customs declaration service fee issued by the entrusted customs declaration unit).

　　 （4） The sales accounting vouchers, sales sub ledgers and other materials of export enterprises can prove that the goods have been sold (hereinafter referred to as sales supporting materials).

　　 It should be noted that if the taxpayer is unable to obtain an export contract for the export of overseas warehouse business, it can choose to use the overseas warehouse order form, proprietary documents of the self operated overseas warehouse, lease agreement of the overseas warehouse or other relevant materials that can support the use of the overseas warehouse for document filing. If the taxpayer is unable to obtain other documents, other documents with similar contents or functions can be used for filing.

　　 8、 Is it necessary for taxpayers to submit sales supporting documents when applying for export tax refund (exemption) for goods exported by means of export overseas warehouses?

　　 When taxpayers apply for export tax refund (exemption), they do not need to submit sales supporting documents. According to the Announcement, if a taxpayer applies for handling export pre refund of tax in accordance with the method of "tax refund upon departure and sales re accounting", it shall complete the retention of sales supporting documents for the tax authorities to check within 15 days after the goods are sold; For those who apply for export tax refund (exemption) according to the current regulations, they shall complete the retention of sales supporting documents for the tax authorities' verification within 15 days after applying for export tax refund (exemption).

　　 9、 What should be done if a taxpayer fails to retain sales supporting documents in accordance with the regulations when applying for export pre refund?

　　 If a taxpayer fails to retain sales supporting materials according to the regulations, it shall be handled according to the taxpayer's failure to file documents according to the regulations, that is, according to the provisions of Article 5 (8) of the Announcement of the State Administration of Taxation on Relevant Issues of the Measures for the Administration of Value Added Tax and Consumption Tax on Exported Goods and Services (No. 12 of 2013), the export tax rebate (exemption) policy is no longer applicable to this export business, The tax exemption policy is applied instead. If tax refund (exemption) has been declared, the negative declaration shall be used to offset the original declaration.

　　 10、 For the export overseas warehouse business for which the taxpayer has declared the export pre rebate, the tax authority finds that the sales supporting documents retained by the taxpayer are forged and false after verification. What should be done?

　　 According to the provisions of the Announcement, taxpayers shall retain the sales supporting documents as the filing documents of export tax rebate (exemption) for the export overseas warehouse business for which export tax pre rebate is declared for future reference. After verification, it is found that the sales supporting documents retained by the taxpayer are forged and false, the tax authority shall deal with them according to the false filing documents provided by the taxpayer, that is, in accordance with Article 7 (1) of the Notice of the Ministry of Finance and the State Administration of Taxation on the VAT and Consumption Tax Policies for Export Goods and Services (CS [2012] No. 39), And Item (9) of Article 5 of the Announcement of the State Administration of Taxation on Relevant Issues of the Measures for the Administration of Value Added Tax and Consumption Tax on Exported Goods and Services (No. 12 of 2013), which stipulates that the export business is no longer subject to the export tax rebate (exemption) policy, but is subject to the taxation policy instead. If it is verified that tax fraud is involved, it shall be handled in accordance with the relevant provisions.

　　 11、 Is it necessary for taxpayers to submit foreign exchange collection materials when applying for export tax refund (exemption) for goods exported through overseas warehouses?

　　 If a taxpayer exports by means of export overseas warehouse, it is not necessary to submit foreign exchange collection materials when applying for export tax rebate (exemption), except for the special circumstances specified in Paragraph 1 to Paragraph 3 of Item (2) of Article 8 of the Announcement of the State Administration of Taxation on Further Facilitating the Handling of Export Tax Rebates to Promote the Steady Development of Foreign Trade (No. 9 of 2022).

　　 12、 Can taxpayers implement "tax refund upon departure" for goods exported before the implementation of the Announcement?

　　 The Announcement shall come into force on January 27, 2025. Taxpayers who export goods by means of export overseas warehouses before the implementation of the Announcement but have not yet declared export tax rebate (exemption) shall declare and handle export tax rebate (exemption) in accordance with the "tax rebate upon departure" method.

　 　 For example:

　　 An export enterprise exports goods in the form of overseas warehouse. The export date indicated on the export goods declaration form issued by the customs is December 20, 2024. As of January 27, 2025 (i.e. the date of implementation of the Announcement), the enterprise has not declared export tax rebate (exemption) for the export goods. When applying for export tax rebate (exemption) on February 20, 2025, the enterprise shall apply for "tax rebate upon departure". For the goods that have been sold, the enterprise shall apply for export tax refund (exemption) in accordance with the current regulations when handling the declaration; For the goods that have not been sold, the enterprise shall first declare the export pre rebate according to the method of "tax refund upon departure, sales re accounting", and then conduct tax accounting according to the actual sales situation.