Many factories regard export tax rebates as "a sum of money that will be paid after exporting." In fact, tax rebates have never been automatically said: they are taxes that companies can get back after declaring according to the deadline, vouchers, and regulations. Starting from January 1, 2026, the "Value Added Tax Law" and its Implementation Regulations, Announcement No. 11 of the Ministry of Finance and the State Administration of Taxation in 2026, and Announcement No. 5 of the State Administration of Taxation in 2026 will be implemented simultaneously, and the institutional framework for export tax rebates will be reshaped as a whole. The most critical change is that in the past, if we didn't pay attention to declarations, we would at most refund less tax; if we don't pay attention, we may change from "no tax refund" to "tax collection."
1. New regulations framework: three documents determine the pattern
The division of labor among the three documents is clear. Announcement No. 11 of 2026 of the Ministry of Finance and the State Administration of Taxation governs entity policies, namely which export businesses can be refunded, exempted, and taxed, and how to define the tax refund rate and scope of application. At the same time, it abolished Caishui [2012] No. 39 and Caishui [2014] No. 98 and other old documents. Announcement No. 5 of 2026 of the State Administration of Taxation governs the procedures, namely the "Measures for the Administration of Value-added Tax and Consumption Tax Refunds (Exemption) for Export Business", which belongs to the filing, declaration, certification, and document retention. The value-added tax law and its implementing regulations are the basis of higher-level law, elevating export tax rebates from the level of administrative regulations to the level of legal. There are three most direct changes to enterprises: the scope of declaration has been expanded from "export goods and services" to "export business", covering cross-border sales of services and intangible assets; the filing has been merged from five simplified forms into one general filing form; nine types of certificates are all electronic.
2. Two deadlines: normal reporting period and 36-month remedial window
| case | period | Consequences of failure to declare on time |
|---|---|---|
| Normal declaration | From the month following the date of customs declaration for export, and within each value-added tax declaration period before April 30 of the following year, collect all vouchers and collect foreign exchange in accordance with regulations | Those who fail to collect foreign exchange before April 30 of the following year shall pay back the refunded (exempted) tax |
| Extended remedy | After April 30 of the following year, within each value-added tax declaration period within 36 months from the date of customs declaration for export, collect all vouchers and provide foreign exchange collection materials at the same time | You can continue to apply, but you need to supplement the collection materials, which will make the procedures heavier. |
| more than 36 months | no | It is regarded as selling goods domestically and must pay value-added tax and consumption tax as required |
Here are three points that are easily misinterpreted. First, the 36-month period is the remedial window, not "there are still three years to slowly handle it." The normal application period is still before April 30 of the following year. The later the application, the greater the uncertainty. Second, the 36-month period is calculated based on natural days from the date of customs declaration for export, not based on the entire month. The critical date should be calculated accurately based on the date of customs declaration. Third, the new regulations will be implemented from January 1, 2026, subject to the export date; businesses exported on or before December 31, 2025 will still be implemented in accordance with the original policy, and the 36-month tax requirement is not applicable. The first thing for companies that do cross-year document sorting is to cut their business into two sections according to the export date, and not mix old and new rules.
3. Collection of foreign exchange has become a constituent element of tax refund
The new regulations include "collection of foreign exchange in accordance with regulations" into the conditions for applying the tax refund (exemption) policy. This is a change with a lot of signal: in the past, collection of foreign exchange was a financial issue, but now collection of foreign exchange is a tax issue. Those who fail to collect foreign exchange within the prescribed time limit must not only pay back the tax refund, but also provide foreign exchange collection materials when applying for overdue remedies. The actual impact on the factory is two: First, the accounting path of advance payments, final payments, commissions, and freight charges must be clear, and irregular methods such as third-party collection and private account collection will be stuck in the declaration process; Second, for large-scale equipment orders with the accounting period of more than one year, it is necessary to plan in advance the matching of the collection rhythm and the tax refund declaration rhythm, and consult the specific guidelines of the competent tax authority when necessary.
4. Documents and filing: Don't forget the rule of retaining it for ten years
The procedural requirements can be summarized into four things. There are three types of declaration channels. The national unified electronic taxation bureau, the standard version of the "single window" for international trade, and the offline export tax refund declaration tool are all free. Small and medium-sized factories use a single window most smoothly. The application materials are divided into two categories according to the tax refund (exemption) method. Production enterprises use the tax refund exemption method and submit summary tables and detailed tables; foreign trade enterprises use the tax refund exemption method and submit export details and purchase details. Filing documents must be retained in accordance with regulations. Purchase and sales contracts, export goods transport documents, entrusted customs declaration documents, and foreign exchange receipts must be retained for ten years. The last one is the easiest to ignore and the easiest to cause problems during tax verification: retention is not about stuffing paper forms into cabinets, but can be quickly retrieved according to the customs declaration number and invoice number. It is recommended to use electronic ledger according to the customs declaration. Dimension archive.
5. How to calculate the tax refund account in the quotation
Tax rebates are part of price competitiveness, but they are not a source of profit. These two things must be distinguished. The basic logic when quoting is: the input tax included in the domestic procurement cost will be refunded at the tax refund rate after export, and the part of the difference between the tax refund rate and the tax rate constitutes the cost. For example: If a product has a tax rate of 13%, and an export tax refund rate of 9%, then 9 points will be refunded out of 13 points in the procurement process, and the remaining 4 points will be accumulated as costs. This part must be reflected in the quotation and cannot be calculated as gross profit according to "Full tax refund". Conversely, if it is a category with zero tax refunds or cancelled tax refunds, the quotation must include all input tax into the cost, otherwise one ticket will be lost for every ticket issued. In addition, there are two disciplines: do not use tax refunds as price reduction space to give customers in advance. There is a period of time for tax refunds to be received, but customers 'price reduction will take effect immediately; and do not write statements such as "including tax refunds and profits" in the quotation. If there is a problem in the application process, the promise cannot be fulfilled, and the customer relationship will be damaged.
6. Common questions
1. Is export tax rebates automatically received? What do I need to take the initiative?
Not automatic. It is necessary to complete the filing of export tax refunds (exemptions) first, and then collect all the vouchers and declare them within the specified time limit. After declaration, the refund can be made only after review. Export business occurring before filing can still apply the tax refund policy as required after completing the filing. However, the scope of tax refund is related to the identity of the taxpayer (such as the effective time when general taxpayer qualifications take effect). It is recommended to file as soon as possible after the export business occurs without delay.
2. What will I do if the documents are incomplete or the invoices are problematic?
Depending on the situation. If the vouchers are incomplete, they cannot be declared temporarily, and can be declared after they are collected within the time limit, or go through extended remedial procedures; if forged or false filing documents or false foreign exchange collection materials are provided, they are under circumstances where taxation policies are applicable, and value-added tax and consumption tax must be paid according to domestic sales are completely different in nature. Therefore, it is better to declare late than use non-compliant documents to make up the declaration.
3. The export business of the factory is entrusted to a foreign trade company as an agent. Who does the tax refund belong to?
Depends on the proxy model. If the foreign trade company only charges agency fees and does not bear the risks and profits and losses of the goods, the entrusting party (factory) will usually declare the tax refund and must obtain the certificate of agency export goods and other information as required; if the foreign trade company purchases and re-exports on its own, it will declare itself. The implementation details of this part vary from place to place. It is recommended to clarify the ownership of tax refunds, declaration responsibilities and data transmission time limit in the agency agreement, rather than just talking about agency fees.
