STA Interpretation: Export Tax Refund/Exemption Matters Supporting Cross-Border E-Commerce Overseas Warehouse Development

关于《国家税务总局关于支持跨境电商出口海外仓发展出口退（免）税有关事项的公告》的解读

Source (Chinese): STA Policy Database — 政策解读 (Goods and Services Tax Division, January 27, 2025)

English translation: Independent translation. Not an official government translation.

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To better leverage the positive role of export tax refunds in supporting the development of cross-border e-commerce exports via overseas warehouses (hereinafter "overseas warehouse exports"), the State Taxation Administration has issued the Announcement on Export Tax Refund/Exemption Matters Supporting Cross-Border E-Commerce Overseas Warehouse Development (hereinafter the "Announcement"), clarifying matters related to export tax refund/exemption for goods exported via the overseas warehouse method (customs supervision code "9810," the same hereinafter). The relevant contents are interpreted as follows:

Q1: How should taxpayers declare and process export tax refund/exemption for goods exported via the overseas warehouse method?

Answer: When taxpayers export goods via the overseas warehouse method, they may declare and process export tax refund/exemption based on the export goods customs declaration form and other relevant materials and information after the goods have cleared customs and departed the territory. When doing so in practice, taxpayers should determine the specific declaration and processing method based on the sales status of the goods: if the goods have been sold at the time of declaring export tax refund/exemption, the taxpayer shall declare and process export tax refund/exemption in accordance with existing regulations; if the goods have not yet been sold, the taxpayer shall declare and process export tax refund/exemption using the "refund upon departure, reconciliation upon sale" method — i.e., first using the export goods customs declaration form and other materials and information to pre-declare and process export tax refund/exemption (hereinafter "export pre-refund"), and subsequently reconciling the tax amount based on the actual sales of the goods.

Q2: How should taxpayers declare and process the export pre-refund?

Answer: Taxpayers shall declare and process the export pre-refund with the tax authority based on the export goods customs declaration form bearing customs supervision code "9810" and other relevant materials and information. When declaring, the following points should be noted: First, when completing the declaration detail form, the taxpayer shall enter the "Overseas Warehouse Pre-Refund" identifier in the "Refund/Exemption Business Type" field, with the business type code: HWC-YT. Second, the taxpayer shall distinguish between goods that have been sold and goods that have not yet been sold, and file separate export pre-refund declarations and export tax refund/exemption declarations respectively; where no distinction is made, all goods shall be treated as unsold and subject to a unified export pre-refund declaration. Third, where the taxpayer is a manufacturing enterprise, a separate declaration sequence number shall be used for the export pre-refund declaration; where the taxpayer is a foreign trade enterprise, a separate correlation number shall be used for the export pre-refund declaration.

Q3: Where goods under the same item number on an export goods customs declaration form have not been entirely sold, how should the taxpayer declare and process the export pre-refund?

Answer: For goods under the same item number on an export goods customs declaration form, the taxpayer may distinguish between the sold portion and the unsold portion: the sold portion shall be declared for export tax refund/exemption in accordance with existing regulations; the unsold portion shall be declared for export pre-refund. Where the taxpayer does not make such a distinction, all goods may be treated as unsold and subject to a unified export pre-refund declaration.

Illustrative Example: A manufacturing enterprise exports 100 tea cups under the same item number of the same export goods customs declaration form. The export date stated on the customs declaration form is February 25, 2025. The enterprise plans to file an export tax refund/exemption declaration for this shipment on March 10, 2025.

Scenario 1: As of March 10, 2025, of the 100 tea cups exported by the enterprise, 20 have been sold and the remaining 80 have not yet been sold. When filing the export tax refund/exemption declaration on March 10, the enterprise shall declare exemption-credit-refund for the 20 sold tea cups in accordance with existing regulations, and declare export pre-refund for the 80 unsold tea cups using the "refund upon departure, reconciliation upon sale" method. When completing the declaration detail form, the enterprise should note the following: first, when filing the export pre-refund declaration for the 80 unsold tea cups, the "HWC-YT" identifier shall be entered in the "Refund/Exemption Business Type" field of the declaration detail form; second, separate declaration sequence numbers shall be used for the 20 sold tea cups and the 80 unsold tea cups.

Scenario 2: When filing the export tax refund/exemption declaration on March 10, the enterprise does not distinguish which of the 100 tea cups have been sold and which have not. In this case, the enterprise may treat all 100 tea cups as subject to export pre-refund under the "refund upon departure, reconciliation upon sale" method. When declaring, the enterprise shall enter the "HWC-YT" identifier in the "Refund/Exemption Business Type" field of the declaration detail form and use the same declaration sequence number for all 100 tea cups.

Q4: When should taxpayers who have declared and processed export pre-refund complete the reconciliation?

Answer: Taxpayers who have declared and processed export pre-refund shall complete the reconciliation within the VAT filing periods prior to the end of the reconciliation period. The reconciliation period specifically refers to the period from the first day of the month following the month in which the tax authority finalized the export pre-refund to April 30 of the following year. In practice, taxpayers may complete the reconciliation during any VAT filing period within the reconciliation period, but no later than the VAT filing deadline in April of the year following the year in which the tax authority finalized the export pre-refund. With the approval of the tax authority, foreign trade enterprises may complete the reconciliation at any time within the reconciliation period, without being restricted to VAT filing periods.

Illustrative Example:

Scenario 1: A manufacturing enterprise declared export pre-refund on February 10, 2025. The tax authority reviewed the enterprise's export pre-refund declaration in accordance with existing regulations. Upon review, no issues were found, and the tax authority finalized the export pre-refund for the enterprise on February 13, 2025. The manufacturing enterprise may complete the reconciliation during any VAT filing period between March 2025 and April 2026, but no later than the VAT filing deadline in April 2026.

Scenario 2: A foreign trade enterprise declared export pre-refund on December 31, 2025. The tax authority reviewed the enterprise's export pre-refund declaration in accordance with existing regulations. Upon review, no issues were found, and the tax authority finalized the export pre-refund for the enterprise on January 2, 2026. The foreign trade enterprise may complete the reconciliation during any VAT filing period between February 2026 and April 2027, but no later than the VAT filing deadline in April 2027. With the approval of the tax authority, the enterprise may complete the reconciliation at any time between February 2026 and April 2027, without being restricted to VAT filing periods.

Q5: How should taxpayers process the export pre-refund reconciliation?

Answer: To help taxpayers process the reconciliation accurately and efficiently, the tax authorities push a data list of export pre-refunds that have been finalized by the tax authority but not yet reconciled by the taxpayer through information systems such as the Electronic Tax Bureau and the International Trade "Single Window."

Taxpayers shall confirm whether the goods have been sold and whether the export pre-refund requires adjustment based on actual sales conditions, and handle the matter according to the following different scenarios:

1. Where the goods have been sold and the export tax refund/exemption amount calculated based on actual sales shows no difference from the export pre-refund amount, the taxpayer shall select and submit the "No Adjustment Required" option in the information system for confirmation, thereby completing the reconciliation procedures.

2. Where the goods have been sold but the export tax refund/exemption amount calculated based on actual sales differs from the export pre-refund amount, the taxpayer shall select and submit the "Adjustment Required" option in the information system for confirmation, and file an adjustment declaration to complete the reconciliation procedures.

3. Where the goods have still not been sold, the taxpayer shall select and submit the "Adjustment Required" option in the information system for confirmation, and repay the full amount of the export pre-refund to complete the reconciliation procedures. After the goods are subsequently sold, the taxpayer shall re-declare and process export tax refund/exemption in accordance with existing regulations, and the "refund upon departure, reconciliation upon sale" method shall no longer apply.

Illustrative Example: A manufacturing enterprise exported 100 tea cups via overseas warehouse and declared export pre-refund on March 10, 2025, with a pre-refund amount of RMB 1,300. Upon review, no issues were found, and the tax authority finalized the export pre-refund of RMB 1,300 for the enterprise on March 14, 2025. The enterprise plans to process the export pre-refund reconciliation on December 12, 2025.

Scenario 1: On December 12, 2025, at the time of reconciliation, all 100 tea cups for which export pre-refund was processed have been sold. The export tax refund/exemption amount calculated based on actual sales is RMB 1,300, showing no difference from the previously processed export pre-refund. In this case, the taxpayer shall select and submit the "No Adjustment Required" option in the information system for confirmation, thereby completing the reconciliation procedures.

Scenario 2: On December 12, 2025, at the time of reconciliation, all 100 tea cups for which export pre-refund was processed have been sold. The export tax refund/exemption amount calculated based on actual sales is RMB 1,235, which differs from the previously processed export pre-refund of RMB 1,300. In this case, the taxpayer shall select and submit the "Adjustment Required" option in the information system for confirmation, and file an adjustment declaration. When filing the adjustment declaration, the enterprise shall first submit an exemption-credit-refund declaration entry with an export tax refund/exemption amount of -1,300 to fully offset the previously submitted export pre-refund declaration data; then, based on the actual sales, submit a new exemption-credit-refund declaration entry with an export tax refund/exemption amount of RMB 1,235. Without considering other factors, the enterprise's declared refund/exemption amount for the current period of December 2025 is -65 (-65 = -1,300 + 1,235). After the tax authority approves the declaration, the enterprise shall carry forward this -65 refund/exemption amount to participate in export tax refund/exemption calculations in subsequent periods.

Scenario 3: On December 12, 2025, at the time of reconciliation, all 100 tea cups for which export pre-refund was processed have been sold. The export tax refund/exemption amount calculated based on actual sales is RMB 1,365, which differs from the previously processed export pre-refund of RMB 1,300. In this case, the taxpayer shall select and submit the "Adjustment Required" option in the information system for confirmation, and file an adjustment declaration. When filing the adjustment declaration, the enterprise shall first submit an exemption-credit-refund declaration entry with an export tax refund/exemption amount of -1,300 to fully offset the previously submitted export pre-refund declaration data; then, based on actual sales, submit a new exemption-credit-refund declaration entry with an export tax refund/exemption amount of RMB 1,365. Without considering other factors, the enterprise's refund/exemption amount for the current period of December 2025 is RMB 65 (65 = -1,300 + 1,365). After the tax authority approves the declaration, it shall process an export tax refund/exemption of RMB 65 for the enterprise in accordance with existing regulations.

Scenario 4: On December 12, 2025, at the time of reconciliation, of the 100 tea cups for which export pre-refund was processed, 30 have been sold and 70 have not. For the 30 sold tea cups, the export tax refund/exemption amount calculated based on actual sales is RMB 390, which differs from the previously processed export pre-refund of RMB 1,300. In this case, the taxpayer shall select and submit the "Adjustment Required" option in the information system for confirmation, and file an adjustment declaration. When filing the adjustment declaration, the enterprise shall first submit an exemption-credit-refund declaration entry with an export tax refund/exemption amount of -1,300 to fully offset the previously submitted export pre-refund declaration data; then, based on the actual sales, submit a new exemption-credit-refund declaration entry with an export tax refund/exemption amount of RMB 390. Without considering other factors, the enterprise's refund/exemption amount for the current period of December 2025 is -910 (-910 = -1,300 + 390). After the tax authority approves the declaration, the enterprise shall carry forward this -910 refund/exemption amount to participate in export tax refund/exemption calculations in subsequent periods. For the 70 unsold tea cups, the enterprise shall declare and process export tax refund/exemption in accordance with existing regulations after the goods are sold.

Q6: How should the situation be handled where the taxpayer fails to complete the export pre-refund reconciliation within the prescribed period?

Answer: Where the taxpayer fails to complete the export pre-refund reconciliation within the prescribed period, the tax authority shall recover the export pre-refund already processed. After the goods are sold, the taxpayer shall declare and process export tax refund/exemption in accordance with existing regulations.

Q7: What backup documentation should taxpayers retain when declaring and processing export tax refund/exemption for goods exported via overseas warehouse?

Answer: The backup documentation that taxpayers should retain for export tax refund/exemption includes:

1. Purchase and sales contracts of the export enterprise (including: export contracts, foreign trade comprehensive service contracts, foreign trade enterprise purchase contracts, manufacturing enterprise purchase contracts for non-self-produced goods for export, etc.).

2. Transportation documents for export goods (including: ocean bills of lading, airway bills, railway consignment notes, cargo receipt documents, postal receipts, and other cargo documents issued by carriers; domestic transportation invoices for freight borne by the export enterprise; international freight forwarding service fee invoices for costs borne by the export enterprise, etc.).

3. Documents related to the export enterprise's entrustment of other entities for customs declaration (including: customs declaration entrustment agreements, agency customs declaration service fee invoices issued by the entrusted customs declaration entity, etc.).

4. Sales accounting vouchers, sales detail ledgers, and other materials that can substantiate that the goods have been sold (hereinafter "sales substantiation materials") of the export enterprise.

It should be noted that where the taxpayer is unable to obtain an export contract for overseas warehouse export business, the taxpayer may use overseas warehouse booking orders, self-owned overseas warehouse ownership documents, leased overseas warehouse lease agreements, or other relevant materials that can substantiate the use of the overseas warehouse for backup documentation purposes. Where the taxpayer is unable to obtain other documents, materials with similar content or function may be used for backup documentation purposes.

Q8: When declaring and processing export tax refund/exemption for goods exported via the overseas warehouse method, are taxpayers required to submit sales substantiation materials?

Answer: Taxpayers are not required to submit sales substantiation materials when declaring and processing export tax refund/exemption. Under the Announcement, where taxpayers declare and process export pre-refund using the "refund upon departure, reconciliation upon sale" method, they shall complete the retention of sales substantiation materials within 15 days after the goods have been sold, to be available for tax authority verification. Where taxpayers declare and process export tax refund/exemption in accordance with existing regulations, they shall complete the retention of sales substantiation materials within 15 days after declaring export tax refund/exemption, to be available for tax authority verification.

Q9: How should the situation be handled where the taxpayer has declared export pre-refund but fails to retain sales substantiation materials as required?

Answer: Where the taxpayer fails to retain sales substantiation materials as required, this shall be treated as a failure to maintain backup documentation as required — i.e., in accordance with Article 5, Paragraph (8) of the STA Announcement on Issues Concerning the Management Measures for VAT and Consumption Tax on Export Goods and Services (2013 Announcement No. 12), the export transaction shall no longer be eligible for the export tax refund/exemption policy and shall instead be subject to the tax exemption policy. Where a refund/exemption has already been declared, the original declaration shall be offset using a negative-amount declaration.

Q10: For overseas warehouse export transactions for which the taxpayer has declared export pre-refund, how should the situation be handled where the tax authority discovers upon verification that the sales substantiation materials retained by the taxpayer are forged or fraudulent?

Answer: Under the Announcement, for overseas warehouse export transactions for which export pre-refund has been declared, the taxpayer shall retain the sales substantiation materials as export tax refund/exemption backup documentation for inspection. Where verification reveals that the sales substantiation materials retained by the taxpayer are forged or fraudulent, the tax authority shall treat this as the taxpayer having provided false backup documentation — i.e., in accordance with Article 7, Paragraph (1), Item 4 of the Notice of the Ministry of Finance and the State Taxation Administration on VAT and Consumption Tax Policies for Export Goods and Services (Cai Shui [2012] No. 39) and Article 5, Paragraph (9) of the STA Announcement on Issues Concerning the Management Measures for VAT and Consumption Tax on Export Goods and Services (2013 Announcement No. 12), the export transaction shall no longer be eligible for the export tax refund/exemption policy and shall instead be subject to the taxation policy. Where the conduct is verified to constitute tax evasion or fraud, it shall be handled in accordance with the corresponding regulations.

Q11: When declaring and processing export tax refund/exemption for goods exported via the overseas warehouse method, are taxpayers required to submit foreign exchange collection materials?

Answer: When taxpayers export goods via the overseas warehouse method and declare export tax refund/exemption, they are not required to submit foreign exchange collection materials, except where any of the special circumstances specified in Article 8, Paragraph (2), Items 1 through 3 of the STA Announcement on Further Facilitating Export Tax Refund Processing and Promoting Stable Foreign Trade Development (2022 Announcement No. 9) apply.

Q12: Can goods exported before the Announcement takes effect be eligible for the "refund upon departure" treatment?

Answer: The Announcement takes effect on January 27, 2025. For goods exported via the overseas warehouse method before the Announcement takes effect but for which export tax refund/exemption has not yet been declared, the taxpayer shall declare and process export tax refund/exemption in accordance with the "refund upon departure" method.

Illustrative Example: An export enterprise exports goods via the overseas warehouse method. The export date stated on the customs declaration form is December 20, 2024. As of January 27, 2025 (the effective date of the Announcement), the enterprise has not yet filed an export tax refund/exemption declaration for this shipment. When the enterprise declares export tax refund/exemption on February 20, 2025, it shall process the declaration using the "refund upon departure" method. Specifically, for goods that have been sold, the enterprise shall declare and process export tax refund/exemption in accordance with existing regulations; for goods that have not yet been sold, the enterprise shall first declare export pre-refund using the "refund upon departure, reconciliation upon sale" method, and subsequently reconcile the tax amount based on the actual sales.