STA Interpretation: Export VAT/Consumption Tax Refund Management Measures

关于《国家税务总局关于发布〈出口业务增值税和消费税退（免）税管理办法〉的公告》的解读

Source (Chinese): STA Policy Database — 政策解读 (Goods and Services Tax Division, January 30, 2026)

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

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In accordance with the VAT Law of the People's Republic of China and other relevant laws and regulations, as well as the Announcement of the Ministry of Finance and the State Taxation Administration on Policies for VAT and Consumption Tax on Export Transactions (MOF/STA Announcement [2026] No. 11, hereinafter the "MOF/STA Announcement"), the STA has issued the Announcement on the Publication of the Management Measures for VAT and Consumption Tax Refund (Exemption) on Export Transactions (hereinafter the "Announcement"), clarifying matters related to VAT and consumption tax refund (exemption) on export transactions (hereinafter "export tax refund/exemption"). The interpretation is as follows:

Q1: What are the main contents of the Announcement?

Answer: The Announcement consists of eight chapters. Chapter 1 — General Provisions, which sets out the policy basis and scope of application for export tax refund/exemption. Chapter 2 — Export Tax Refund/Exemption Registration, which specifies provisions on new registration, changes to registration, and withdrawal of registration for export tax refund/exemption. Chapter 3 — Export Tax Refund/Exemption Declaration, which specifies provisions on declaration materials, acceptance of declarations, and withdrawal of declarations. Chapter 4 — Processing of Export Tax Refund/Exemption, which specifies provisions on the review and processing of export tax refund/exemption by tax authorities. Chapter 5 — Export Tax Refund/Exemption Certificate Management, which specifies provisions on the issuance, reissuance, and cancellation of nine categories of certificates. Chapter 6 — Export Tax Refund/Exemption Services and Management Matters, which specifies the free declaration channels available to taxpayers, fully online processing, policy reminders and other convenient services, as well as management requirements for backup documentation and foreign exchange collection for export tax refund/exemption. Chapter 7 — Other Provisions and Handling of Violations, which specifies requirements for taxpayers who waive refund/exemption or tax exemption, and provisions on the handling and penalties for non-compliant conduct. Chapter 8 — Supplementary Provisions, which specifies the format for submission of textual materials, management of deemed export goods, and the effective date of the Announcement.

Q2: What principles does the Announcement follow?

Answer: The Announcement primarily follows these principles: First, overall continuity with appropriate consolidation. The existing export tax refund/exemption management provisions are generally maintained, while management documents issued across different periods have been consolidated and integrated into a unified set of management measures, making it easier for taxpayers to understand and comply. Second, alignment with policy and concurrent adjustment. Strict alignment with the VAT Law, the Implementation Regulations, and export tax policies ensures that the corresponding export tax refund/exemption management provisions are adjusted with adequate legal basis and full compliance. Third, responding to concerns with pragmatic optimization. Focusing on resolving concentrated appeals and suggestions from taxpayers, incorporating beneficial experience accumulated from grassroots tax authority administration practices, and optimizing certain management provisions to enhance the operability and relevance of the Announcement and improve service and management effectiveness.

Q3: What adjustments has the Announcement made regarding export tax refund/exemption registration?

Answer: The Announcement generally maintains the existing provisions on export tax refund/exemption registration, with targeted optimization adjustments based on taxpayer feedback. The main changes include: First, streamlining and consolidating registration forms. The five separate registration forms under the previous rules — export tax refund/exemption registration, specific business registration (group company member enterprise registration, duty-free goods enterprise registration, entrusted agency refund registration, and prior-refund-then-verification qualification application) — have been consolidated into a single universal Export Tax Refund/Exemption Registration Form, enabling "one-form handling" for all registration matters. The supporting materials required for eight categories of specific entities such as R&D institutions have been consolidated into a single Export Tax Refund/Exemption Registration Supporting Materials Checklist, enabling "one-list clarity" for supporting materials. Second, optimizing and adjusting registration change requirements. Under the previous rules, taxpayers were required to settle all export tax refund/exemption amounts before applying to change their refund/exemption method, and could not declare refund/exemption for export transactions occurring before the change. Given practical situations where certain objective factors make it genuinely impossible to settle tax amounts immediately, or where taxpayers mistakenly selected the wrong refund/exemption method due to unfamiliarity with policies when initially filing their registration, the Announcement adds exception clauses to the above general rule, specifying that for export transactions with specific circumstances, after reporting to the tax authority, taxpayers need not settle export tax refund/exemption amounts before the change and may continue to declare and process export tax refund/exemption after the change.

Q4: When should taxpayers complete export tax refund/exemption registration? What information and materials must be submitted?

Answer: Taxpayers should complete export tax refund/exemption registration when making their first export tax refund/exemption declaration or when applying to obtain export tax refund/exemption certificates. When registering, taxpayers must truthfully submit the Export Tax Refund/Exemption Registration Form to the competent tax authority, and depending on the specific export business circumstances, submit the corresponding supporting materials listed in the Export Tax Refund/Exemption Registration Supporting Materials Checklist.

Illustrative Example 1: A foreign trade enterprise was established and completed tax registration on January 5, 2026. On January 8, it exported a batch of goods under general trade on its own account, and planned to make its first export tax refund/exemption declaration on February 2. The enterprise could complete export tax refund/exemption registration immediately after completing tax registration on January 5, and must complete registration no later than when making its first export tax refund/exemption declaration on February 2. Since there are no supporting material requirements for goods exported on its own account under general trade, the enterprise only needs to truthfully submit the Export Tax Refund/Exemption Registration Form.

Illustrative Example 2: A foreign trade enterprise was established and completed tax registration on January 5, 2026. On January 8, it sold design services on a cross-border basis, and planned to make its first export tax refund/exemption declaration on February 2. The enterprise could complete export tax refund/exemption registration immediately after completing tax registration on January 5, and must complete registration no later than when making its first export tax refund/exemption declaration on February 2. Since the enterprise sold design services on a cross-border basis, in addition to the Export Tax Refund/Exemption Registration Form, it must also submit the cross-border service sales contract signed with the overseas entity, the Technology Export Contract Registration Certificate and its data sheets corresponding to the cross-border service sales income, and other supporting materials.

Illustrative Example 3: A manufacturing enterprise was established and completed tax registration on January 5, 2026, and planned to entrust a foreign trade comprehensive service enterprise to handle export tax refund/exemption matters on its behalf. The enterprise could complete export tax refund/exemption registration immediately after completing tax registration on January 5, and must complete registration no later than when first entrusting the agency to process the refund. When registering, the enterprise only needs to truthfully submit the Export Tax Refund/Exemption Registration Form. Note that when filling out the registration form, in addition to completing the fields for basic export tax refund/exemption information, the enterprise must also select "Manufacturing Enterprise Entrusting Agency Refund" under the export tax refund/exemption management type, and complete the fields related to entrusted agency refund information.

Illustrative Example 4: A manufacturing enterprise had already completed export tax refund/exemption registration and entrusted agency refund registration in January 2024. After the Announcement publishes the new Export Tax Refund/Exemption Registration Form, the enterprise is not required to re-register for export tax refund/exemption or entrusted agency refund using the new form.

Q5: When a taxpayer applies to change its refund/exemption method, how should export transactions that occurred prior to the change be handled?

Answer: When a taxpayer changes its refund/exemption method, unless the circumstances specified in Article 9 of the Announcement apply, the taxpayer must settle all export tax refund/exemption amounts before applying for the change, and may not declare refund/exemption for export transactions that occurred before the change after the change is processed.

Illustrative Example: A manufacturing enterprise, due to adjusting its business model, applied on April 1, 2026 to change its registered refund/exemption method from exemption-credit-refund to exemption-refund. If no special circumstances specified in Article 9 of the Announcement exist, the enterprise must settle the export tax refund/exemption amounts for all export transactions that occurred before April 1. After the competent tax authority confirmed that the enterprise had settled all export tax refund/exemption amounts, it processed the change on April 3. After completing the change on April 3, the enterprise may declare export tax refund/exemption for export transactions occurring on or after April 1 that are subject to the exemption-refund method, in accordance with that method.

Q6: When a taxpayer is unable to settle export tax refund/exemption amounts prior to applying for a change of refund/exemption method due to special circumstances, how should this be handled?

Answer: Where export transactions occurring before the taxpayer's application to change the refund/exemption method involve any of the following circumstances, after the taxpayer submits the Report on Exported but Unsettled Refund/Exemption Transactions to the competent tax authority, the reported export transactions need not be settled before the change and may continue to be declared and processed for export tax refund/exemption after the change:

1. The taxpayer has not yet collected all export tax refund/exemption declaration documents, declaration supporting materials, or foreign exchange collection materials, and is temporarily unable to declare export tax refund/exemption.

2. The taxpayer has declared export tax refund/exemption, but due to tax audit, export tax correspondence investigation, or other reasons, the competent tax authority is temporarily unable to finalize the export tax refund/exemption.

3. The taxpayer has already begun operating under the post-change business model within thirty days prior to applying for the change.

4. An error in the refund/exemption method registration was discovered before the competent tax authority's first approval of export tax refund/exemption.

Illustrative Example 1: A foreign trade enterprise, due to adjusting its business model, applied on April 1, 2026 to change its registered refund/exemption method from exemption-refund to exemption-credit-refund. However, for a shipment exported on March 15, the enterprise had not yet obtained the special VAT invoice issued by the upstream supplier and was temporarily unable to declare export tax refund/exemption. In this case, the enterprise may submit the Report on Exported but Unsettled Refund/Exemption Transactions to the competent tax authority for that export transaction. After submission, the enterprise may proceed with the refund/exemption method change without settling the export tax refund/exemption amount for that transaction. Once the enterprise collects the special VAT invoice and other declaration documents, it may declare and process the export tax refund/exemption for that transaction under the exemption-refund method.

Illustrative Example 2: A foreign trade enterprise, due to adjusting its business model, applied on April 1, 2026 to change its registered refund/exemption method from exemption-refund to exemption-credit-refund. However, one of its declared transactions was under correspondence investigation by the competent tax authority and could not be finalized before the change. In this case, the enterprise may submit the Report on Exported but Unsettled Refund/Exemption Transactions to the competent tax authority for that transaction and proceed with applying for the refund/exemption method change. After the change, the enterprise continues to process the export tax refund/exemption for that transaction under the exemption-refund method.

Illustrative Example 3: A manufacturing enterprise, due to a strategic business adjustment, began operating under a foreign trade enterprise model starting March 15, 2026. The enterprise applied on April 1 to change its registered refund/exemption method from exemption-credit-refund to exemption-refund. The enterprise may submit the Report on Exported but Unsettled Refund/Exemption Transactions to the competent tax authority for export transactions conducted under the foreign trade enterprise model during the period from March 15 to April 1. After submission, the export transactions during that period may be declared and processed for export tax refund/exemption under the exemption-refund method after the change.

Illustrative Example 4: A manufacturing enterprise mistakenly selected the exemption-refund method — which did not match its actual business model — when completing export tax refund/exemption registration on April 1, 2026. After completing the registration, the enterprise had not made any export tax refund/exemption declarations. On April 10, the enterprise discovered the error and immediately applied to the competent tax authority to change its refund/exemption method. It submitted the Report on Exported but Unsettled Refund/Exemption Transactions to the competent tax authority for export transactions that had already occurred. After submission, those export transactions may be declared and processed for export tax refund/exemption under the exemption-credit-refund method after the change.

Q7: When a taxpayer applies to change its competent tax authority and some export transactions have not yet been declared for export tax refund/exemption, to which tax authority should these transactions be declared?

Answer: When a taxpayer applies to change its competent tax authority, the original competent tax authority shall finalize any export tax refund/exemption matters already applied for by the taxpayer, and then process the registration change. Export tax refund/exemption matters not yet applied for by the taxpayer shall be applied for and processed by the new competent tax authority after the change.

Q8: What adjustments has the Announcement made regarding export tax refund/exemption declarations?

Answer: The Announcement generally maintains the existing provisions on export tax refund/exemption declarations, and has made supporting adjustments and optimizations to certain declaration forms and requirements based on export tax policy changes and taxpayers' actual declaration needs. The main changes include: First, improving declaration forms. In response to new policy provisions allowing the exemption-credit-refund method for in-orbit delivery of spacecraft and related goods, and for space transportation services, the relevant fields in detailed declaration forms have been adjusted to meet the declaration needs for these export transactions under the exemption-credit-refund method. Second, refining declaration requirements. For special circumstances where foreign trade enterprises apply the exemption-credit-refund method, the refund/exemption declaration requirements have been specified in detail: generally following the exemption-credit-refund declaration requirements for manufacturing enterprises; in addition, for purchased goods, the Foreign Trade Enterprise Export Tax Refund Purchase Detail Declaration Form must also be submitted.

Q9: What declaration materials should taxpayers submit when declaring exemption-credit-refund for in-orbit delivery of spacecraft and related goods?

Answer: Taxpayers applying the exemption-credit-refund method for in-orbit delivery of spacecraft and related goods shall submit the following declaration materials:

1. Exemption-Credit-Refund Declaration Summary Form.

2. Manufacturing Enterprise Export Goods and Repair Services Exemption-Credit-Refund Declaration Detail Form.

3. Export invoice or ordinary invoice.

4. Materials required by the Export Tax Refund/Exemption Declaration Supporting Materials Checklist, specifically: (a) the signed in-orbit delivery contract (if the in-orbit delivery contract has a corresponding project list, the project list shall also be provided); (b) payment receipt for income received from the entity with which the in-orbit delivery contract was signed.

5. Other materials required by the municipal-level or higher tax authority.

Q10: What declaration materials should taxpayers submit when declaring exemption-credit-refund for space transportation services?

Answer: Taxpayers applying the exemption-credit-refund method for space transportation services shall submit the following declaration materials:

1. Exemption-Credit-Refund Declaration Summary Form.

2. International Transportation (Hong Kong, Macau, Taiwan Transportation), Space Transportation Exemption-Credit-Refund Declaration Detail Form.

3. Export invoice or ordinary invoice.

4. Materials required by the Export Tax Refund/Exemption Declaration Supporting Materials Checklist, specifically: (a) the signed launch contract (if the launch contract has a corresponding project list, the project list shall also be provided); (b) payment receipt for income received from the entity with which the launch contract was signed.

5. Other materials required by the municipal-level or higher tax authority.

Q11: When a foreign trade enterprise directly exports services or self-developed intangible assets, it is treated as a manufacturing enterprise and applies the exemption-credit-refund method uniformly for its export goods. What declaration materials should the foreign trade enterprise submit when declaring exemption-credit-refund?

Answer: When a foreign trade enterprise declares exemption-credit-refund, it shall follow the exemption-credit-refund declaration requirements for manufacturing enterprises by reference, and declare exemption-credit-refund in accordance with Articles 16 and 17 of the Announcement. For purchased goods, the Foreign Trade Enterprise Export Tax Refund Purchase Detail Declaration Form must also be submitted.

Illustrative Example: A foreign trade enterprise completed export tax refund/exemption registration in January 2024, with its registered enterprise type as "Foreign Trade Enterprise" and its refund/exemption method as "Exemption-Refund." In February 2026, having developed R&D capabilities, the enterprise began directly selling R&D services to overseas entities for services entirely consumed outside China. Under the MOF/STA Announcement, the enterprise applies the exemption-credit-refund method uniformly for its R&D services together with its export goods. When the enterprise changed its export tax refund/exemption registration that month, it changed the refund/exemption method from "Exemption-Refund" to "Exemption-Credit-Refund," while the enterprise type remained unchanged as "Foreign Trade Enterprise."

Scenario 1: On March 10, 2026, when the enterprise declared exemption-credit-refund for R&D services directly sold to overseas entities and entirely consumed outside China, it was required to submit the following declaration materials:

1. Exemption-Credit-Refund Declaration Summary Form.

2. Cross-Border Sales of Services and Intangible Assets Exemption-Credit-Refund Declaration Detail Form; Cross-Border Sales of Services and Intangible Assets Revenue Receipt Detail List.

3. Export invoice or ordinary invoice.

4. Materials required by the Export Tax Refund/Exemption Declaration Supporting Materials Checklist, specifically: (a) the R&D contract signed with the overseas entity; (b) the Technology Export Contract Registration Certificate and its data sheets corresponding to the service income; (c) payment receipt for income received from the overseas entity with which the R&D contract was signed.

5. Other materials required by the municipal-level or higher tax authority.

Scenario 2: On March 10, 2026, when the enterprise declared exemption-credit-refund for both the R&D services directly sold to overseas entities and entirely consumed outside China, and the purchased export goods together, in addition to the declaration materials listed in Scenario 1, it was also required to submit the relevant declaration materials in accordance with the provisions for manufacturing enterprises declaring export goods refund/exemption, and to simultaneously submit the Foreign Trade Enterprise Export Tax Refund Purchase Detail Declaration Form for the purchased export goods.

Q12: What declaration materials should taxpayers submit when declaring consumption tax refund/exemption?

Answer: Taxpayers declaring consumption tax refund/exemption shall do so concurrently with the corresponding VAT refund/exemption declaration, and submit the following declaration materials:

1. For those applying the exemption-credit-refund method, the Export Non-Self-Produced Goods Consumption Tax Refund Declaration Form shall be submitted, along with the Tax Payment Certificate (Export Goods and Services Special Use) or the Export Goods Tax Payment Split Certificate, customs import consumption tax special payment certificate, and the withholding tax payment certificate for taxable consumer goods recovered from entrusted processing, as applicable based on actual business circumstances.

2. For those applying the exemption-refund method, the Foreign Trade Enterprise Export Tax Refund Export Detail Declaration Form and the Foreign Trade Enterprise Export Tax Refund Purchase Detail Declaration Form shall be submitted, along with the Tax Payment Certificate (Export Goods and Services Special Use) or the Export Goods Tax Payment Split Certificate, and the customs import consumption tax special payment certificate, as applicable based on actual business circumstances.

Q13: How should taxpayers handle errors discovered in export tax refund/exemption declarations?

Answer: Taxpayers should handle this differently depending on whether the declaration has been approved by the competent tax authority: First, if the declaration has not yet been approved by the competent tax authority, the taxpayer shall submit the Application to Withdraw Export Tax Refund/Exemption Declaration, selecting "Withdrawal due to declaration error" as the withdrawal reason, to apply for withdrawal. The competent tax authority shall process the withdrawal provided no circumstances warranting denial of refund/exemption are found. Second, if the declaration has already been approved by the competent tax authority, the taxpayer shall offset the original declaration data using negative amounts.

Declaration documents involved in declarations that have been withdrawn or offset with negative amounts may subsequently be reused for export tax refund/exemption declarations.

Q14: How should taxpayers handle sales returns for export transactions for which export tax refund/exemption has already been processed?

Answer: Where a sales discount, suspension, or return occurs for an export transaction for which export tax refund/exemption has already been processed, the taxpayer shall offset the original export tax refund/exemption declaration data using negative amounts in the month the event occurs or the following month. After the offset, if the current period's refund/exemption amount is negative, taxpayers applying the exemption-credit-refund method shall carry it forward to offset against future periods, while taxpayers applying the exemption-refund method shall repay the tax. If the refund/exemption amount is positive, the competent tax authority shall process the export tax refund/exemption in accordance with regulations.

Illustrative Example 1: A foreign trade enterprise exported a batch of clothing in January 2026, declared export tax refund/exemption of RMB 5,000 in February, and the tax authority approved and processed the RMB 5,000 export tax refund/exemption that month. In June, the entire batch of clothing was returned because the sizes did not meet the foreign buyer's requirements. The enterprise should offset the original refund/exemption declaration data using negative amounts in June or July.

Scenario 1: In July, the enterprise submitted a declaration entry with an export tax refund/exemption amount of -5,000 to offset the original declaration. Concurrently, the enterprise submitted another declaration entry for other export transactions with an export tax refund/exemption amount of RMB 7,000. The enterprise's current period refund/exemption amount for July was RMB 2,000 (2,000 = -5,000 + 7,000). After review and approval by the tax authority, a refund of RMB 2,000 was processed for the enterprise.

Scenario 2: In July, the enterprise submitted a declaration entry with an export tax refund/exemption amount of -5,000 to offset the original declaration. Concurrently, the enterprise submitted another declaration entry for other export transactions with an export tax refund/exemption amount of RMB 3,000. The enterprise's current period refund/exemption amount for July was -2,000 (-2,000 = -5,000 + 3,000). After review and approval by the tax authority, the enterprise was required to repay tax of RMB 2,000.

Illustrative Example 2: A manufacturing enterprise exported a batch of clothing in January 2026, declared export tax refund/exemption of RMB 5,000 in February, and the tax authority approved and processed the RMB 5,000 export tax refund/exemption that month. In June, the entire batch of clothing was returned because the sizes did not meet the foreign buyer's requirements. The enterprise should offset the original refund/exemption declaration data using negative amounts in June or July.

Scenario 1: In July, the enterprise submitted a declaration entry with an export tax refund/exemption amount of -5,000 to offset the original declaration. Concurrently, the enterprise submitted another declaration entry for other export transactions with an export tax refund/exemption amount of RMB 7,000. The enterprise's current period refund/exemption amount for July was RMB 2,000 (2,000 = -5,000 + 7,000). After review and approval by the tax authority, a refund/exemption of RMB 2,000 was processed for the enterprise.

Scenario 2: In July, the enterprise submitted a declaration entry with an export tax refund/exemption amount of -5,000 to offset the original declaration. Concurrently, the enterprise submitted another declaration entry for other export transactions with an export tax refund/exemption amount of RMB 3,000. The enterprise's current period refund/exemption amount for July was -2,000 (-2,000 = -5,000 + 3,000). After review and approval by the tax authority, the enterprise was required to carry the -2,000 refund/exemption amount forward to offset against future periods.

Q15: How should export tax refund/exemption be handled when the tax authority discovers that a taxpayer is suspected of accepting fraudulently issued special VAT invoices and has been placed under investigation?

Answer: Where the competent tax authority discovers that a taxpayer is suspected of accepting fraudulently issued special VAT invoices and has been placed under investigation by the tax authority with the case not yet resolved, the export transactions involved shall not be processed for export tax refund/exemption. For those already processed, the competent tax authority shall temporarily withhold an amount equal to the refund amount involved from the taxpayer's other approved refund amounts. The competent tax authority may proceed with processing export tax refund/exemption or release the temporarily withheld refund amounts only after verifying and clearing the suspicious issues.

Illustrative Example: A foreign trade enterprise declared export tax refund/exemption for a batch of exported clothing on January 4, 2026. The purchase documents corresponding to that declaration included two special VAT invoices, with a corresponding refund amount of RMB 2,000. On January 9, the enterprise was placed under investigation for suspected acceptance of fraudulently issued special VAT invoices. The invoices under investigation were the two special VAT invoices used in the January 4 export tax refund/exemption declaration, with a corresponding refund amount of RMB 2,000.

Scenario 1: At the time the enterprise was placed under investigation on January 9, the export tax refund/exemption declared on January 4 had not yet been finalized. The competent tax authority shall not process the RMB 2,000 refund corresponding to that export transaction until the tax authority verifies and clears the relevant suspicious issues.

Scenario 2: At the time the enterprise was placed under investigation on January 9, the export tax refund/exemption declared on January 4 had already been fully processed. However, another declaration of RMB 3,000 in export tax refund/exemption filed on January 8 had been reviewed and approved but not yet fully processed. The competent tax authority shall temporarily withhold RMB 2,000 from the enterprise's approved refund amounts, corresponding to the refund amount associated with the invoices under investigation.

Q16: Under what circumstances should the competent tax authority suspend all export tax refund/exemption processing for a taxpayer?

Answer: Where the competent tax authority discovers that a taxpayer has any of the following circumstances, export tax refund/exemption processing shall be suspended for the taxpayer:

1. The taxpayer's status is classified as an abnormal household (non-compliant taxpayer).

2. The taxpayer has overdue export tax refund/exemption amounts that should have been repaid but remain outstanding.

3. The taxpayer refuses to cooperate with the tax authority in conducting export tax refund/exemption-related inspections.

4. Other circumstances as specified by the State Taxation Administration.

Illustrative Example: A newly established enterprise refused to cooperate with the competent tax authority's on-site inspection when making its first export tax refund/exemption declaration. After being ordered to rectify within a specified period, the enterprise continued to refuse the inspection, preventing the competent tax authority from confirming whether the enterprise met the conditions for refund/exemption. Until the enterprise cooperates with the inspection, the competent tax authority shall suspend processing of all its export tax refund/exemption transactions. Processing will resume after the enterprise cooperates with the inspection.

Q17: What adjustments has the Announcement made regarding export tax refund/exemption certificate management?

Answer: The Announcement generally maintains the existing provisions on applying for and issuing export tax refund/exemption certificates, and has made adjustments and optimizations to certain certificate application and issuance provisions based on export tax refund/exemption policy changes and deepened cooperation between the tax and customs authorities. The main changes include: First, full digitization of certificates. Building on the electronic issuance of six categories of certificates already achieved in 2022, and in light of new developments in data sharing between tax authorities and customs and other departments, the remaining three categories of certificates — the Certificate of Approval for Tax-Free Purchase of Export Cigarettes, the Certificate of Tax-Exempt Export Cigarettes, and the Certificate of Tax Repaid/Not Refunded for Export Goods — may now also be issued and used electronically. Second, adjustment of certificate processing deadlines. Based on the policy provision that VAT shall be payable if a refund/exemption or tax exemption for exported goods is not declared within thirty-six months from the date of customs clearance, the Announcement concurrently specifies that the entrusted party in a consignment export arrangement shall apply for the Certificate of Agency Export Goods within thirty-six months from the date the goods clear customs on export.

Q18: What free and convenient declaration channels may taxpayers choose for export tax refund/exemption?

Answer: Taxpayers may choose from three free declaration channels to handle export tax refund/exemption matters: the nationally unified standardized Electronic Tax Bureau, the standard version of the International Trade "Single Window," and the offline export tax refund declaration tool.

Q19: What reminder services related to export tax refund/exemption may taxpayers enjoy?

Answer: Tax authorities provide taxpayers with free reminder services including export tax refund/exemption policy updates, export tax refund rate database upgrades, notifications about customs declarations of export goods not yet used for export tax refund/exemption declarations, and confirmation of finalized export tax refund/exemption. Taxpayers may choose to subscribe to specific reminder service content. These reminder services are provided for taxpayer reference only and do not serve as a basis for processing export tax refund/exemption matters.

Q20: How should taxpayers manage backup documentation for export goods and outbound repair services that are subject to export tax refund/exemption policies?

Answer: Taxpayers shall, within fifteen days after declaring export tax refund/exemption, properly retain the following backup documentation (except where the taxpayer does not have the corresponding backup documentation due to the nature of the transaction terms), and prepare a backup documentation directory organized by the chronological order of export tax refund/exemption declarations, indicating the storage method for the backup documentation, for inspection by the tax authority.

1. Purchase and sales contracts. 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 taxpayer; international freight forwarding service fee invoices for costs borne by the taxpayer, etc.

3. Documents related to the taxpayer'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.

Where taxpayers are unable to obtain the above backup documentation, other materials with similar content or function may be used as substitutes. Unless otherwise provided, backup documentation shall be stored and maintained by the taxpayer, shall not be destroyed without authorization, and shall be retained for a period of ten years.

Q21: What are the foreign exchange collection requirements for taxpayers declaring export tax refund/exemption for outbound repair services?

Answer: Outbound repair services are subject to foreign exchange collection management by reference to export goods. For outbound repair services declared for refund/exemption, the taxpayer shall collect foreign exchange by April 30 of the year following the year of customs export clearance. Where the taxpayer fails to collect foreign exchange within the prescribed period but the circumstances match those listed in the Deemed Foreign Exchange Collection Reasons and Supporting Materials Checklist, the taxpayer shall retain the Export Transaction Foreign Exchange Collection Report and supporting materials, and the collection shall be deemed completed. Where the export contract stipulates that the final date for full collection is after April 30 of the year following the customs export clearance date, the taxpayer shall complete collection within the period stipulated in the contract, provided it is no later than thirty-six months from the date of customs export clearance.

Q22: How should taxpayers submit foreign exchange collection materials for cross-border sales of services (excluding outbound repair services) and intangible assets that are subject to export tax refund/exemption policies?

Answer: For cross-border sales of services (excluding outbound repair services) and intangible assets that are subject to export tax refund/exemption policies, taxpayers who submit the corresponding payment receipts or original income composition documents and other declaration materials in accordance with Chapter 3 of the Announcement shall be deemed to have submitted the foreign exchange collection materials.