Core conclusions:According to Announcement No. 11 of 2026 of the Ministry of Finance and the State Administration of Taxation, declared export goods should declare tax refunds (exemptions) within each value-added tax declaration period from the month following the date of declaration to April 30 of the following year and collect foreign exchange in accordance with regulations. Those who fail to collect foreign exchange before April 30 of the following year must pay the refunded (exemptions) tax; If the deadline is exceeded, supplementary declarations can also be made within each declaration period within 36 months from the date of customs declaration for export, but the vouchers must be collected and foreign exchange collection materials must be provided at the same time. The 36 months period is calculated as natural days. If the declaration is not made within the time limit, it is deemed to be sales to China, and value-added tax is required. The announcement issued on October 12 also reduced the export tax refund rate for new energy vehicles from 13% to 9% starting from April 1, 2027, defined by the export date indicated in the customs declaration.
1. Timeline of arrival: Three points in time that must be remembered
| node | time limit | What to prepare? |
|---|---|---|
| first declaration | VAT declaration period from the month following the date of export declaration to April 30 of the following year | Customs declarations, export invoices, purchase vouchers, and sales revenue records confirmed in accordance with the accounting system |
| foreign exchange collection | Collect foreign collections in accordance with regulations before April 30 of the following year | Bank collection receipts and foreign exchange memos; tax refund (exemption) must be paid back if the collection fails to be collected on schedule |
| supplementary declaration | From April 30 of the following year to 36 months from the date of customs declaration for export, calculated based on natural days | You must collect all the vouchers and provide foreign exchange collection materials at the same time, and you cannot do anything missing. |
There are four applicable conditions for export tax refunds (exemptions): sales to overseas units or individuals, declaration to customs and actual departure from the country, collection of foreign exchange in accordance with regulations, and the newly clear "sales in accordance with the accounting system" in 2026. The last one makes the compliance requirements in practice explicit: if sales revenue is not recognized in accounting, the chain of vouchers behind it will be broken, and tax refund declarations will become passive water. This is also the starting point for tax review to cross-compare corporate declaration data with customs export data and foreign exchange collection data.
2. How to calculate the tax refund amount: the difference between exemption from refund and exemption from tax refund
Production enterprises shall apply the tax exemption method. Tax exemption refers to exemption from export value-added tax; tax deduction refers to the first deduction of the input tax corresponding to exported goods from domestic value-added tax; tax refund refers to the refund of the inexhaustible part. For example: a production enterprise's current domestic sales revenue is 1 million yuan, export sales revenue is 2 million yuan, and the input tax on domestically purchased raw materials is 300,000 yuan. The tax rate and export tax refund rate are both 13%. The tax refund exemption amount, that is, the tax refund upper limit is 200 × 13% = 260,000 yuan; the domestic sales tax is 100 × 130,000 yuan, and 13 − 30 = − 170,000 yuan is the tax allowance at the end of the period; the tax allowance is less than the tax refund upper limit, the current tax refund amount is 170,000 yuan, and the current tax exemption amount is 26 − 17 = 90,000 yuan.
Foreign trade enterprises shall apply tax refund exemption measures. The value-added tax on export links is exempted, and the value-added tax paid in domestic procurement links is refunded. If there is no "offset" link, the calculation is more direct. It should be noted that when the tax refund rate is lower than the applicable tax rate, the difference will be transferred out of input tax and included in the cost of export business. This area is most likely to be missed when quoting, and the actual amount received will be higher than that calculated directly based on the tax refund rate. The figure is lower.
The announcement on October 12 gave a clear window for new energy-related categories: starting from April 1, 2027, the export tax rebate rate for new energy vehicles will be reduced from 13% to 9%, and export tax rebates for e-cigarette equipment and other products will be cancelled. The announcement clarified that the tax refund rate is defined based on the export date indicated in the export goods declaration form, that is, orders declared before March 31, 2027 (inclusive) will still be calculated at 13%. If a difference of 4 percentage points falls into the quotation model, it is a block of gross profit. Factories involving relevant categories should review their production scheduling and delivery arrangements for the first quarter of next year based on this.
3. Collection of foreign exchange: the three easiest pits to step on
- Failure to collect foreign exchange on schedule:If foreign exchange is not received before April 30 of the following year, the tax refund will have to be paid back, and the production enterprise will have to transfer out the deducted input tax. This is not a matter of fines, it is a two-way squeeze of cash flow.
- Foreign exchange collection materials omitted in the supplementary application:For supplementary declarations after April 30, the conditions will be changed from "collect foreign exchange in accordance with regulations" to "collect all vouchers + provide foreign exchange collection materials." Nothing less can be done, and we can only wait until the materials are complete before submitting.
- The collection entity is inconsistent with the contract entity:In the case of payment by an overseas affiliated company or payment by a third party, information that can explain the authenticity of the transaction needs to be prepared in advance, otherwise it will be stuck during the verification of foreign exchange collection.
4. Five common reasons for rejection of declarations
- Documents are not filed as required:The filing document is the basis of review. If it is missing, it will be replenished. If it is not replenished, it can only be converted to tax exemption.
- The name of the customs declaration and the transportation document is inconsistent:If the name and specifications on bills of lading and other documents are revised after customs clearance, resulting in inconsistency between the two contents, they will be dealt with in accordance with the taxation policy, and the refund will be refunded.
- Sales not recognized in accordance with the accounting system:Only customs declarations and collections were made, and sales revenue was not confirmed in accounting. The chain was broken from the first step, which was a high-risk doubt.
- The price is obviously high and without justifiable reasons:If the domestic purchase price or export price is obviously high and no reasonable explanation can be provided, the business will be subject to a tax exemption policy and no tax refund will be made.
- Fake self-employed real agent:Those who have not actually participated in export business activities and do not bear any of the risks of quality, collection or tax refund, the tax refunds that have been refunded will be refunded, and those that have not been refunded will not be processed.
5. Common questions
1. Is export tax rebates automatically received?
No. It is necessary to declare itself within the specified time limit, and at the same time meet the four conditions of sales to overseas units or individuals, customs declaration and actual departure from the country, confirmation of sales in accordance with the accounting system, and collection of foreign exchange in accordance with regulations. After declaration, the tax authorities will cross-compare the tax refund data with customs export data and foreign exchange collection data, and supplementary materials will be returned if there is any mismatch in any link.
2. Is it impossible to refund it after April 30 of the following year?
You can still make up. After April 30 of the following year and within 36 months from the date of customs declaration for export, if you have received all the vouchers and provided foreign exchange collection materials, you can still apply for processing. However, 36 months are calculated based on natural days, and those that are not declared within the time limit will be regarded as sales to China, and value-added tax and consumption tax will be paid. It is recommended to keep a ledger according to the customs declaration date and mark out the customs declaration forms that are due each month to avoid discovering them before the deadline.
3. Will export orders in 2025 still be subject to a 36-month limit?
No. Export businesses that declare customs declaration for export before December 31, 2025 (including the same day) and apply tax refund (exemption) or tax exemption policies will still be implemented in accordance with the original policy. Failure to declare within a 36-month period is not applicable. Provisions that tax on domestic sales will be deemed to be levied. Export business occurring from January 1, 2026 will be implemented in accordance with the new regulations.
For exporting factories, tax refunds are not after-the-fact work of the financial department, but a piece of income that should be included in the quotation process: putting the declaration period, foreign collection node and tax refund rate changes in the same table is much easier than making amends at the end of the year.
Qihang Zhilian Foreign Trade Research Institute·Let China's intelligent manufacturing industry set sail to sea·Tel: 180-0327-6609
