Export tax rebates are one of the most direct sources of profit for foreign trade companies. When selling a piece of equipment, a one-percentage-point difference in the tax rebate rate can mean a difference of tens of thousands or even hundreds of thousands.. The 2026 tax refund policy is undergoing a systematic overhaul; if you don’t understand it, you’ll either end up with less money or run into trouble and face an audit.The

On August 6, the Hunan Provincial Tax Bureau of the State Taxation Administration clarified during a briefing that the framework for the export tax rebate system for 2026 has been systematically restructured.. To sum it up in one sentence:If you didn’t take it seriously in the past, the worst that could happen was “a smaller tax refund”; if you don’t take it seriously now, it could go from “no tax refund” to “having to pay taxes.”The

Business owners and finance professionals in the foreign trade and wholesale sectors must make sure they understand this calculation.

I. Six Key Changes to Export Tax Rebates in 2026

Change 1: Tax rebates for 271 products have been eliminated or reduced

Announcement No. 2 of 2026 issued by the Ministry of Finance and the State Taxation Administration specifies that, effective April 1, 2026, export tax rebates for 249 products will be eliminated, and the export tax rebate rates for 22 products, including batteries, will be gradually reduced to zero.The

Specifically: Export tax rebates for products such as photovoltaic equipment will be eliminated outright; for battery products, the rebate rate will be reduced from 9% to 6% from April 1 to December 31, 2026, and eliminated effective January 1, 2027. Additionally, the measures cover chemical raw materials and organic compounds (approximately 90 items), plastics and polymer materials (approximately 7 items), stone and slate products (approximately 13 items), building materials and thermal insulation products (approximately 30 items), ceramics (approximately 36 items), and glass and glass products (approximately 50 items). Relevant companies need to adjust their export product categories and pricing in advance.The

Change 2: The scope of reporting has been expanded from “exported goods and services” to “export transactions.”

Cross-border sales services and intangible assets have also been included. Export services provided by foreign trade enterprises may be eligible for tax exemption, credit, and refund—Tax rebates are also available for technical services provided overseas—this represents a new source of profit.The

Change 3: A 36-month strict deadline; any delay will be treated as domestic sales for tax purposes

This is the most critical red line to watch out for in this new policy. According to Announcement No. 11 of 2026 issued by the Ministry of Finance and the State Taxation Administration, for new export transactions effective January 1, 2026, the filing deadline for tax refunds and tax exemptions has been changed to 36 months. Specifically, if a tax refund or exemption is not claimed within 36 months from the date of customs clearance for export, Value-Added Tax (VAT) and Consumption Tax must be paid on the day following the expiration of the 36-month period, in accordance with the provisions governing deemed domestic sales.

It is important to note that 36 months is the deadline for corrective action, not a grace period. The standard filing deadline remains April 30 of the year following the export; for late corrective action, additional documentation regarding foreign exchange receipts must be provided.. Export transactions conducted on or before December 31, 2025, will continue to be governed by the original policy, and the 36-month provision will not apply.

Change 4: Document Filing Has Been Significantly Simplified, but the Retention Period Has Been Extended

Announcement No. 11 repealed old documents such as Cai Shui [2012] No. 39,Five filing forms have been consolidated into one., All 9 types of certificates have been digitized, and filing efficiency has improved by approximately 55%. However, the record-keeping requirements have become stricter—purchase and sales contracts, shipping documents, customs declaration documents,Retain for 15 days after filing; the retention period is up to 10 years....which effectively extends the compliance responsibility to cover an entire cycle, with audits capable of tracing back at any timeThe

Change 5: Lower Entry Thresholds for Precious Metals and Natural Diamonds

The proportion of costs attributable to precious metals and natural diamonds in raw materials decreased from 80% to 50% or more.. Since most precious metals are classified as non-refundable items in the tax refund rate database, the inventory structure needs to be recalculated.The

Change 6: Risk control reviews have become significantly stricter

The General Administration of Customs and the State Taxation Administration have established real-time data sharing, and efforts to crack down on “fake exports for real tax refunds” have been stepped up.. Exporting certain categories of goods through specific ports may trigger an automated verification.; If an upstream supplier is placed on the risk list, your tax refund may also be suspendedThe

II. For a single export transaction, the outcome may be a tax refund, tax exemption, or taxation.

The tax authorities' position is very clear:Compliance is the “lifeline” that allows companies to reap the benefits of government policies.”The

• Tax Refunds (or Exemptions): When all four conditions—“sold, cleared through customs, recorded in the books, and payment received”—are met, the refund amount depends on the tax refund rate, and the speed of the refund depends on compliance and documentation.The
• Tax-Free: If goods are exported but do not meet the conditions for a tax refund, or if they are subject to statutory tax exemption, the input tax cannot be claimed as a deduction and must be included in the cost of goods sold.The
• Taxation: No refund or exemption; in cases of non-compliance or statutory circumstances, VAT shall be paid as if the goods were sold domestically.The

Note: Tax-exemption is not a “free lunch”; rather, it means absorbing input tax into your costs. If you can qualify for a tax refund, don’t settle for the tax-exemption tier lightly.The

III. Five Red Lines That Must Not Be Crossed

The consequences of tax fraud are extremely severe—the refunded tax amount will be recovered, and a fine of one to five times the amount of tax fraudulently obtained will be imposed; if the act constitutes a crime, criminal liability will be pursued in accordance with the law.The

Five Red Lines: Falsifying invoices, issuing fraudulent invoices, overstating the value of low-value goods, falsely reporting foreign exchange receipts, and forging documentsThe

lit. the four streams coincide (idiom); fig. the four streams are identicalThis is the baseline for compliance: the flow of goods, the flow of funds, the flow of documents, and the flow of information must all corroborate one another.. Regulation has expanded from the trade sector to the entire international logistics chain, and any discrepancy at any stage may trigger an investigation.The

IV. These Industries Have Been Most Severely Affected

Photovoltaic Industry: Starting April 1, tax refunds will be eliminated outright, and this will have an immediate impact.

Battery Industry: 9% → 6% → 0%, phased reduction, with a complete phase-out beginning in 2027.

The chemical, building materials, ceramics, and glass industries, among others: Tax rebates for dozens to hundreds of product categories have been eliminated or reduced.

EPC (Engineering, Procurement, and Construction) General Contractor: Although the VAT refund rate for most major engineering equipment remains at 13%, the steel structures, building materials, and auxiliary materials used in the project may be affected.. When preparing a bid, be sure to verify the latest tax rebate rate; don’t base your calculations on outdated data—a lower tax rebate rate means higher actual costs.The

V. Three Recommendations for Export Companies

First, immediately conduct an inventory of product tax refund rates. Refer to the “Export Tax Rebate Rates Database, Version 2026A”, verify whether the tax rebate rates for each exported product have changed, particularly for companies in the photovoltaic, battery, chemical, and building materials sectors.

Second, establish a 36-month reporting early-warning mechanism. Streamline internal business processes, establish ledgers, and verify on a monthly basis whether export customs declarations have been filed.. Don't think of the 36-month period as a chance to “take your time”; it's simply the final deadline for remedial action.

Third, strengthen document management and ensure consistency among the four flows. Document retention must be completed within 15 days of filing and documents must be retained for 10 years.. The flow of goods, funds, documents, and information must be mutually corroborative.. It is recommended that document management and foreign exchange receipt tracking be incorporated into daily financial processes rather than handled in a batch at the end of the year.

VI. How Can Qi Cai Ying Help You?

Export tax rebate policies have changed—have you updated your compliance processes?

QCYWith deep expertise in the field of financial and tax compliance, we offer:

• Export Tax Rebate Compliance Review: Conduct a Comprehensive Review of Export Tax Rebate Risk Areas in Enterprises
• Cross-Border Tax and Financial Compliance Consulting: Covering the entire chain, including export tax rebates, value-added tax, and customs duties
• Domestic tax compliance accounts: Ensure consistency among the four flows so that they stand up to audits
• Cross-border e-commerce tax compliance: Customized solutions for models such as the 9610, 9710, and 9810
• Tax and Financial Services for Hong Kong and Overseas Companies: Integrating Domestic and Overseas Operations, Global Expansion

Policy changes present both challenges and opportunities. The sooner you comply, the less risk you face.

Scan the QR code to add us on WeChat: qcy20251218, or call 13045886252 to receive a personalized export tax rebate compliance assessment.

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The Group is deeply committed to providing services across the entire corporate lifecycle. Its core business areas include: business registration, bookkeeping services, tax compliance, overseas company registration (Hong Kong, the U.S., Singapore, Mexico, etc.), cross-border structuring, outbound direct investment (ODI) filing, overseas tax planning, bank account opening assistance, and identity planning.

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This article is based on Announcements No. 2, No. 5, and No. 11 of 2026 issued by the Ministry of Finance and the State Taxation Administration, as well as the explanatory remarks provided by the Hunan Provincial Tax Bureau of the State Taxation Administration. Specific implementation shall be subject to the guidelines of the competent tax authorities.