In 2026, the first year of the official implementation of the Value-added Tax Law, the export tax rebate rules have ushered in a systematic reconstruction. A large number of export enterprises still follow the old declaration logic, unclear collection nodes and non-compliance of document storage, which are very easy to trigger theOverdue deemed domestic sales, limited eligibility for tax rebates, tax audit warningThree major risks. Today we will dismantle the five major practical adjustments based on the two core documents, Ministry of Finance and State Administration of Taxation Announcement No. 11 of 2026 and State Administration of Taxation Announcement No. 5 of 2026, to help enterprises build a compliant, efficient, and traceable export tax refund management structure.

I. Definition of core document

1.1 Cai Shui [2026]11sizeable sum of money

Definition: The core policy document on export tax after the implementation of VAT Law, replacing Cai Shui [2012] No. 39, which unified the rules of export tax refund (exemption) / tax exemption / tax collection, effective from January 1, 2026.

1.2 General Administration of Taxation [2026]5sizeable sum of money

Definition: General document for export tax rebate levy and management, supporting Circular 11, replacing Announcement No. 24 of 2012, unifying the whole process of operation and wind control, effective from January 1, 2026.

Core point: the two documents constitute a "policy + collection and management" closed loop, all the goods declared for export after January 1, 2026, the mandatory application of the new rules; December 31, 2025 before the export of goods, according to the old rules, "collection that is reported", without a fixed deadline. There is no fixed deadline.

II. Five core adjustments

2.1 Export tax refund (exemption) declaration period: from "April of the following year" to "36 months".

Definition: Export tax refund declaration period, refers to the longest window of time in which an enterprise can file a tax refund (exemption) declaration since the date of declaration of goods for export.

Old rules: export in the current year, complete the declaration before the declaration period in April of the following year, and the late date is easily regarded as domestic sales.

New regulation: for exports after January 1, 2026, the tax refund (exemption)/exemption declaration will be completed within 36 months; any overdue period will be taxed as domestic sales.

Delimitation rules: exported before 2025.12.31 → no fixed deadline, documents + collection can be declared at any time.

Core points: 36 months is the ultimate legal deadline, not an indefinite delay; there is no room for remediation after the deadline, and the tax will be paid directly on the basis of domestic sales.

2.2 Extension of deadline for collection of remittances: regular collection until April 30 of the following year

Definition: The deadline for collection of foreign exchange refers to the latest time for enterprises to complete the collection of foreign exchange and submit information on collection of foreign exchange for export operations for which tax refunds have been processed.

Old rules: collection of foreign exchange needs to be completed within the following April filing period.

New rule: The deadline for receiving foreign exchange is extended to April 30 of the following year, which is about 15 days longer than the old rule.

Applicable scenarios: general trade, cross-border e-commerce 9610/9810, FBA headway and other mainstream export modes.

Core Points: Extend the window period for collection of foreign exchange, ease the pressure on enterprises' overseas account period, and reduce the risk of recovering the refunded tax.

2.3 Integration of niche business receipts into tax reimbursement management: microtrade + repair and refurbishment

Definition: To include two types of low-frequency business in the unified collection and supervision of foreign exchange, and to realize the coverage of the whole scenario of export tax rebate.

Inclusion:

1) Small border trade, cross-border e-commerce small orders

(2) Provision of external repair and maintenance services

Management Requirements: Complete the collection of foreign exchange, retain the vouchers and declare for record according to the new regulations before enjoying the tax refund (exemption).

Core Points: Eliminate the regulatory blind spot, the previous gray operation of "small amount of non-receipt of foreign exchange and non-declaration" will be directly triggered by the compliance risk from 2026 onwards.

2.4 Custody period of record documents: 5 years upgraded to 10 years

Definition: Export tax rebate filing documents, including contracts, customs declarations, logistics documents, foreign exchange receipts, etc., are the core basis for tax verification.

Old rules: 5 years of custody.

New rule: 10-year custody period, starting from the year following the year of filing.

Verification Impact: Tax audits can be traced back for 10 years, missing or altered documents will directly lead to unrecognized tax refunds, recovery of taxes + penalties.

Core Points: 10-year retention is a rigid bottom line, and companies must establish an electronic filing system to eliminate the risk of paper loss.

2.5 Rules for Changes in Enterprise Information: Articles 9 and 10 of Document No. 5 Clarify Operation Paths

Definition: Compliance process when there is a change in the name of the enterprise, legal representative, business model, tax refund (exemption) method, etc.

Core requirements:

(1) List of Tax Refund Businesses Required to be Reported Before Changes are Made

(2) Re-filing after changes but without interrupting normal filing

(3) Strictly prohibit the use of changes to avoid verification and transfer of business

Applicable scenarios: M&A and reorganization, cross-region migration, business model switching (pure foreign trade → production-oriented).

Core Points: Information changes are reported first and then changed to avoid tax refund suspension due to process errors.

Three,Comparison table of old and new policies

for the benefit ofcorporationsSome of the landingssuggestion

1. Ledger structure: build the ledger according to the "pre-2026/post-2026" dual-track, mark the 36-month expiration date, and set up automatic early warning.

2. Foreign exchange collection structure: Fixed monthly reconciliation of the progress of foreign exchange collection to ensure that the previous year's collection is completed by April 30th.

3. Documentation architecture: full electronic archiving and retention for 10 years to meet verification requirements.

4. Declaration structure: 9610/9810, FBA/FBM sub-modal accounting to ensure that the caliber of income is consistent with customs declaration and foreign exchange collection.

The 2026 export tax rebate is not a simple relaxation of the deadline, but an upgrade of the underlying structure. Enterprises must shift from "passive tax filing" to "active compliance" and replace fragmented operations with systematic management.