From 5 Years to 10 Years: It’s Not Just the Numbers That Have Changed

The *Value-Added Tax Law* and the *Regulations for the Implementation of the Value-Added Tax Law* will take effect on January 1, 2026, and the supporting policy documents regarding export operations will be implemented accordingly. One change that has a profound impact on export enterprises but is often overlooked is:The retention period for export tax refund (exemption) filing documents has been extended from 5 years to 10 years.The

It is also clarified that the filing documents shall be submitted by the taxpayerStore and safeguard; do not destroy without authorization.The

This means that the tax authorities have effectively doubled the scope of their audits and investigations into export operations. The past assumption that “old records from more than five years ago cannot be retrieved” no longer holds true.

Which documents must be retained?

The primary purpose of filing documents is to verify that “this export transaction is genuine and the supply chain is unbroken.” They typically include, but are not limited to:

• Customs Declaration Form for Export Goods and Related Customs Documents
• Export Invoice, Packing List
• Shipping documents (ocean bills of lading, air waybills, cargo manifests, etc.)
• Domestic shipping documents, supplier shipping slips, and outbound shipment slips
• Purchase Contracts, Sales Contracts
• Foreign Exchange Receipt and Foreign Exchange Settlement Slip
• Agreements Regarding Customs Clearance and Export Services

The key is compatibility, not quantity. When tax authorities conduct an audit, they aren’t looking to see if you have a pile of papers; they’re checking to see if the documents support each other.

Make sure you calculate the start date of the period correctly—don’t get it wrong.

The starting point for the retention period is typically based onFrom the date of filing the application for export tax refund (or exemption)The calculation is based on the date of calculation, not the date of customs declaration for export. This distinction is easy to miscalculate in practice—many finance professionals file documents based on the customs declaration date, only to find that they have already expired under tax regulations.

Recommended Practice: In the month that the tax refund claim is filed, create a separate file for the entire set of documents, noting the filing date and due date, rather than waiting until the end of the fiscal year to organize them all at once.

The consequences of non-compliant documentation are more severe than you might think

Based on recent practices in tax administration and law enforcement, the frequency and depth of export tax rebate audits have both increased. If a company is found to have failed to file its documents in accordance with regulations, the consequences go beyond simply making corrections:

1. Tax-exemption policies apply only to exported goods.... and we couldn't get the tax refund we were originally entitled to
2. We have been required to repay the tax refund we had previously received.
3. In serious cases, this may trigger further verification of the authenticity of business transactions, affecting both the current and prior periods' tax returns.

In other words, the cost of document management is certain, while the cost of missing documents is uncertain.

Three Frequently Asked Questions on the Spot

Question 1: Documents from the operations, procurement, logistics, and finance departments are missing by the time they reach the finance department. This is not something the finance department can resolve on its own; it requires clarifying, at the process level, the responsibilities and deadlines for document submission at each stage.

Question 2: The business model itself is non-compliant, resulting in a mismatch between the documents. For example, in cases of “buy-and-sell” exports or transactions disguised as direct sales but actually conducted as agency arrangements, the documents naturally do not match up, and the discrepancies cannot be resolved. Such risks cannot be eliminated through post-transaction adjustments.

Question 3: The method for archiving electronic documents is unclear. Digital invoices and electronic documents have become the norm, so it is essential to establish clear storage paths, naming conventions, and backup mechanisms to prevent them from being lost following personnel changes.

A Self-Assessment Checklist

• Are the documentation and records for export tax rebates from the past 10 years complete and searchable?
• Is the expiration date clearly indicated on each set of documents?
• Do the commodity names, quantities, and amounts on the customs declaration, export invoice, and shipping documents match?
• Is the export date on the customs declaration earlier than the supplier’s shipment date? (This type of logical inconsistency is a key focus of the verification process.)
• Are there backups and access controls for electronic documents?

If you’re verifying that your materials align with the reporting guidelines, feel free to contact a consultant at Qicaiying (WeChat/Phone: 18676749275), and we’ll walk you through the entire process from start to finish.