When it comes to commissioned exports, the biggest challenge before 2026 isUnclear subject<\/strong>: Who is responsible for exports, who receives the revenue, and who should file the declaration\u2014each party in the chain has its own take on the matter.<\/p>\n This loophole is now being closed in two directions by two rules:<\/p>\n Value-Added Tax (VAT).<\/strong>Article 48, Paragraph 2 of the \u201cRegulations for the Implementation of the Value-Added Tax Law\u201d stipulates: Where a taxpayer exports goods on a consignment basis, the taxpayer shall comply with the provisions of the competent tax authority of the State Council.Procedures for Exporting Through an Agent<\/strong>, the principal shall, in accordance with regulations, file for and process export tax refunds (or exemptions), apply for VAT exemptions, or pay VAT;If the procedures for entrusting an agent to handle exports have not been completed, the shipper of the exported goods shall declare and pay value-added tax in accordance with regulations.<\/strong>The<\/p>\n Corporate Income Tax.<\/strong>The \u201cAnnouncement of the State Taxation Administration on Optimizing Matters Related to Corporate Income Tax Advance Payment Filings\u201d (State Taxation Administration Announcement No. 17 of 2025) stipulates that enterprises exporting goods on an agency basis (including through market procurement trade, comprehensive foreign trade services, and other methods) shall, when filing advance payment returns,Simultaneously submit basic information on the actual export consignees and details regarding export amounts<\/strong>The<\/p>\n If the information is not reported accurately, the enterprise will be deemed to have handled the transaction on a self-operated basis and will be required to pay the corresponding corporate income tax on the export amount. The announcement also addressesActual Exporting Party<\/strong>Definition: Identifies the entity that actually manufactures and sells the exported goods.<\/p>\n The reason lies in data sharing. The regulations and supporting documents clearly stipulate that customs authorities shall provide tax authorities with information on export customs declarations for goods, and that tax authorities may establish mechanisms for sharing VAT-related information and coordinating efforts with multiple departments; tax authorities also have the authority to obtain information from relevant entities and individuals regarding logistics and customs clearance, freight forwarding, and fund settlement related to exported goods or services.<\/p>\n this meansExport data from customs declarations, data pushed by the platform, and companies' tax return data<\/strong>The three parties will come together. The gray-market practices that once thrived on information asymmetry are now very difficult to conceal.<\/p>\n There have already been cases in practice where a cross-border e-commerce company, having no actual export business of its own, lent its corporate name to others so they could use it to obtain government export subsidies based on those parties\u2019 export data. As customs and internet platform data were transmitted to the tax authorities, the tax authorities determined that the company had failed to file tax returns in accordance with the export data declared to customs and required it to pay back taxes on corporate income tax and value-added tax.<\/p>\n For practices such as \u201cbuying invoices\u201d and \u201cinflating export figures,\u201d the risk has shifted from \"possibly being investigated\" to \"being detected with a high degree of probability.\"<\/p>\n Consignor (Actual Cargo Owner):<\/strong><\/p>\n Trustee (Agent):<\/strong><\/p>\n If you\u2019re verifying that your materials align with the reporting guidelines, feel free to contact a consultant at Qicaiying (WeChat\/Phone: 18676749275), and we\u2019ll walk you through the entire process from start to finish.<\/p>","protected":false},"excerpt":{"rendered":" Article 48 of the \u201cRegulations for the Implementation of the Value-Added Tax Law\u201d stipulates that when goods are exported on a consignment basis, the consignment export procedures must be completed, and the principal must file for a tax refund (or exemption); if these procedures are not completed, the shipper must file for and pay the value-added tax. Announcement No. 17 of 2025 issued by the State Taxation Administration requires export agencies to submit information on the actual principal in the export transaction concurrently with their advance tax return. This article explains how these two sets of requirements overlap and outlines the necessary compliance actions.<\/p>","protected":false},"author":10,"featured_media":18266,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[13,17,18,64],"tags":[2358,2359,2360,277],"class_list":["post-18267","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-guide","category-allguide","category-recomguide","category-gf-tax-compliance","tag-2358","tag-2359","tag-2360","tag-277"],"yoast_head":"\nWhy is this line being targeted now?<\/h2>\n
What Each Party\u2014the Principal and the Agent\u2014Must Do<\/h2>\n
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Three Common Risk Areas<\/h2>\n
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Practical Recommendations<\/h2>\n
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