Announcement of the State Taxation Administration on Matters Concerning Supporting the Development of Overseas Warehouses for Cross-Border E-Commerce Exports and Export Tax Refund (Exemption)

　　To better leverage the positive role of export tax refunds in supporting the development of cross-border e-commerce export overseas warehouses (hereinafter referred to as export overseas warehouses), the State Taxation Administration issued the "Announcement of the State Taxation Administration on Matters Concerning Export Tax Refund (Exemption) Supporting the Development of Cross-Border E-Commerce Export Overseas Warehouses" (hereinafter referred to as the "Announcement"), clarifying matters related to export tax refund (exemption) for taxpayers exporting goods by way of export overseas warehouses (customs supervision method code "9810," the same below). The relevant content is interpreted as follows:

　　I. If a taxpayer exports goods by means of an overseas warehouse, how should it file and handle export tax refund (exemption)?

　　For goods exported by taxpayers via overseas warehouses, after the goods are declared and leave the country, they may file for export tax refund (exemption) based on the export goods declaration form and other relevant materials and information. In specific operations, taxpayers shall determine the specific filing method based on the sales status of the goods: when filing for export tax refund (exemption), if the goods have already been sold, file according to current provisions; if the goods have not yet been sold, file for export tax refund (exemption) under the "refund upon departure, settlement upon sale" method, i.e., first file in advance for export tax refund (exemption) based on the export goods declaration form and other materials and information (hereinafter referred to as export advance refund), and later conduct tax settlement based on the goods sales status.

　　II. How shall taxpayers file to handle export advance tax refund?

　　A taxpayer shall declare and process the export advance tax refund to the tax authority on the basis of relevant materials and information such as the export goods customs declaration form with the customs supervision method code "9810". When declaring, attention shall be paid to the following: First, when filling in the declaration detail form, the "overseas warehouse advance refund" identifier shall be filled in the "refund (exemption) business type" column, and the business type code is: HWC-YT. Second, goods not yet sold and goods already sold shall be distinguished, and export advance tax refund declarations and export refund (exemption) declarations shall be made separately; if not distinguished, all shall be deemed as not yet sold and uniformly declared as export advance tax refund. Third, if the taxpayer is a production enterprise, it shall use a separate declaration sequence number to declare the export advance tax refund; if the taxpayer is a foreign trade enterprise, it shall use a separate association number to declare the export advance tax refund.

　　III. For goods under the same item number on the export goods customs declaration form, when not all sales have been realized, how should the taxpayer declare and handle export advance tax refund?

　　For goods under the same item number on the export goods customs declaration, the taxpayer may distinguish between the sold portion and the unsold portion. For the sold portion, file for export tax refund (exemption) per current provisions; for the unsold portion, file for export advance tax refund. If the taxpayer does not make a distinction, all may be treated as unsold and uniformly filed for export advance tax refund.

　　Illustration: A manufacturing enterprise declared the export of 100 teacups through the same item number on the same export goods customs declaration form. The export date stated on the export goods customs declaration form issued by customs is February 25, 2025. The enterprise plans to handle the export tax refund (exemption) declaration for this batch of goods on March 10, 2025.

　　Scenario 1: On March 10, 2025, of the 100 teacups the enterprise had exported, 20 had achieved sales and the remaining 80 had not yet achieved sales. When the enterprise filed for export tax refund (exemption) on March 10, for the 20 teacups that had achieved sales, it filed for exemption, credit, and refund in accordance with current regulations; for the 80 teacups that had not achieved sales, it filed for export advance tax refund in accordance with the "refund upon departure, accounting upon sale" method. When filling out the filing detail form, the enterprise should note: first, when filing the export advance tax refund for the 80 unsold teacups, it should fill in the "HWC-YT" identifier in the "refund (exemption) business type" column of the filing detail form. Second, it should use different filing sequence numbers for the 20 sold teacups and the 80 unsold teacups.

　　Scenario 2: When the enterprise filed for export tax refund (exemption) on March 10, it did not distinguish which of the 100 exported teacups had already been sold and which had not. In this case, the enterprise may file for export advance tax refund for all 100 teacups under the "refund upon departure, reconciliation upon sale" method. When filing, the enterprise shall enter the "HWC-YT" identifier in the "refund (exemption) business type" column of the filing detail form, and use the same filing sequence number for the above 100 teacups.

　　IV. If a taxpayer has already filed for and processed an export advance tax refund, when shall the accounting be handled?

　　Where a taxpayer has declared and processed the export advance tax refund, it shall process the accounting within each VAT tax filing period before the deadline of the accounting period. The above accounting period specifically refers to the period from the 1st day of the month following the tax authority's completion of the export advance tax refund to April 30 of the following year. In practice, the taxpayer may process the accounting in any VAT tax filing period within the accounting period, but no later than the deadline of the VAT tax filing period of April of the year following the tax authority's completion of the export advance tax refund. With the consent of the tax authority, a foreign trade enterprise may process the accounting at any time within the accounting period, without being subject to the VAT tax filing period.

　　Illustration:

　　Scenario 1: A manufacturing enterprise declared export advance tax refund on February 10, 2025. The tax authority reviewed the export advance tax refund declared by the enterprise in accordance with current regulations. After review, there was no problem with this transaction, and the tax authority completed the export advance tax refund for the enterprise on February 13, 2025. At this point, the manufacturing enterprise may handle accounting verification during any VAT tax filing period between March 2025 and April 2026, but no later than the deadline of the April 2026 VAT tax filing period.

　　Scenario 2: A certain foreign trade enterprise filed for export advance tax refund on December 31, 2025. The tax authority reviewed the export advance tax refund filed by the enterprise in accordance with current regulations. After review, there were no issues with this transaction, and the tax authority completed the export advance tax refund for the enterprise on January 2, 2026. At this point, the foreign trade enterprise may conduct accounting verification during any VAT tax filing period between February 2026 and April 2027, but no later than the deadline of the April 2027 VAT tax filing period. With the tax authority's consent, the enterprise may conduct accounting verification at any time between February 2026 and April 2027, without being subject to the restrictions of VAT tax filing periods.

　　V. How do taxpayers handle export advance tax refund accounting?

　　To help taxpayers handle accounting accurately and efficiently, tax authorities push to taxpayers, through information systems such as the Electronic Tax Bureau and the International Trade "Single Window," a list of export pre-refund data that the tax authorities have completed but the taxpayer has not yet accounted for.

　　A taxpayer shall, based on the actual sales situation, confirm whether the goods have been sold and whether the export advance tax refund needs adjustment, and handle the following different situations separately:

　　(1) If the goods have already been sold and there is no difference between the export refund (exemption) amount calculated according to the actual sales situation and the export advance refund amount, the taxpayer may check and submit the option of "no adjustment declaration required" in the information system for confirmation, and the accounting procedures shall be completed immediately;

　　(II) Where the goods have been sold but there is a difference between the export tax refund (exemption) amount calculated based on actual sales and the export advance tax refund amount, the taxpayer shall check and submit the option of "requires adjustment filing" in the information system for confirmation, and after adjustment filing, the accounting procedures shall be completed immediately;

　　(3) If the goods have still not been sold, the taxpayer checks and submits the option "declaration needs adjustment" in the information system for confirmation, and after fully refunding the export advance tax refund, the accounting procedures are completed. After the goods are subsequently sold, the taxpayer shall re-declare and handle the export tax refund (exemption) in accordance with current regulations, and the "refund upon departure, accounting upon sale" method shall no longer apply.

　　Illustration: A manufacturing enterprise exported 100 teacups via overseas warehouse export and declared export advance tax refund on March 10, 2025, with an export advance refund amount of 1,300 yuan. After review, there was no problem with this transaction, and the tax authority completed the export advance tax refund of 1,300 yuan for the enterprise on March 14, 2025. The enterprise plans to handle export advance tax refund accounting verification on December 12, 2025.

　　Scenario 1: On December 12, 2025, during enterprise accounting, all 100 teacups for which export advance tax refund had been processed had achieved sales. The export tax refund (exemption) amount calculated according to actual sales was 1,300 yuan, with no difference from the previously processed export advance tax refund. At this point, after the taxpayer checks and submits the "no adjustment filing required" option in the information system for confirmation, the accounting procedures are completed.

　　Scenario 2: On December 12, 2025, during enterprise accounting, all 100 teacups for which export advance tax refund had been processed had achieved sales. The export tax refund (exemption) amount calculated according to actual sales was 1,235 yuan, which differed from the previously processed 1,300 yuan export advance tax refund. At this point, the taxpayer should check and submit the "adjustment filing required" option in the information system for confirmation and make an adjustment filing. When making the adjustment filing, the enterprise should first submit a batch of exemption, credit, and refund filing data with an export tax refund (exemption) amount of −1,300 yuan to fully offset the previously submitted export advance tax refund filing data; then, based on actual sales, resubmit a batch of exemption, credit, and refund filing data with an export tax refund (exemption) amount of 1,235 yuan. Without considering other influencing factors, the enterprise's refundable (exemptible) tax amount filed for the current period of December 2025 is −65 yuan (−65 yuan = −1,300 yuan + 1,235 yuan). After the tax authority approves it, the enterprise should carry forward this −65 yuan refundable (exemptible) tax amount to the next period for export tax refund (exemption) calculation.

　　Scenario 3: On December 12, 2025, during enterprise accounting, all 100 teacups for which export advance tax refund had been processed had achieved sales. The export tax refund (exemption) amount calculated according to actual sales was 1,365 yuan, which differed from the previously processed 1,300 yuan export advance tax refund. At this point, the taxpayer should check and submit the "adjustment filing required" option in the information system for confirmation and make an adjustment filing. When making the adjustment filing, the enterprise should first submit a batch of exemption, credit, and refund filing data with an export tax refund (exemption) amount of −1,300 yuan to fully offset the previously submitted export advance tax refund filing data; then, based on actual sales, resubmit a batch of exemption, credit, and refund filing data with an export tax refund (exemption) amount of 1,365 yuan. Without considering other influencing factors, the enterprise's refundable (exemptible) tax amount for the current period of December 2025 is 65 yuan (65 yuan = −1,300 yuan + 1,365 yuan). After the tax authority approves it, it should process an export tax refund (exemption) of 65 yuan for the enterprise in accordance with current regulations.

　　Scenario 4: On December 12, 2025, during enterprise accounting, of the 100 teacups for which export advance tax refund had been processed, 30 had achieved sales and 70 had not. For the 30 teacups that had achieved sales, the export tax refund (exemption) amount calculated according to actual sales was 390 yuan, which differed from the previously processed 1,300 yuan export advance tax refund. At this point, the taxpayer should check and submit the "adjustment filing required" option in the information system for confirmation and make an adjustment filing. When making the adjustment filing, the enterprise should first submit a batch of exemption, credit, and refund filing data with an export tax refund (exemption) amount of −1,300 yuan to fully offset the previously submitted export advance tax refund filing data; then, based on actual sales, resubmit a batch of exemption, credit, and refund filing data with an export tax refund (exemption) amount of 390 yuan. Without considering other influencing factors, the enterprise's refundable (exemptible) tax amount for the current period of December 2025 is −910 yuan (−910 yuan = −1,300 yuan + 390 yuan). After the tax authority approves it, the enterprise should carry forward this −910 yuan refundable (exemptible) tax amount to the next period for export tax refund (exemption) calculation. For the 70 teacups that had not achieved sales, the enterprise should, after they achieve sales, file for export tax refund (exemption) in accordance with current regulations.

　　VI. How should a taxpayer handle the situation if it fails to complete the export advance tax refund accounting within the prescribed time limit?

　　Where a taxpayer fails to process the export advance tax refund accounting within the prescribed time limit, the tax authority shall recover the export advance tax refund already processed; after the goods are sold, the taxpayer shall declare and process the export refund (exemption) in accordance with current regulations.

　　VII. What filing documents must a taxpayer retain when applying for export tax refund (exemption) for goods in overseas warehouses?

　　The export refund (exemption) filing documents that a taxpayer shall retain include:

　　(1) Purchase and sales contracts of export enterprises (including: export contracts, comprehensive foreign trade service contracts, purchase contracts of foreign trade enterprises, purchase contracts for export of non-self-produced goods acquired by production enterprises, etc.).

　　(2) Transport documents for export goods (including: ocean bills of lading, air waybills, railway waybills, cargo carrier documents, postal receipts and other cargo documents issued by carriers, domestic transport invoices for freight paid by export enterprises, invoices for international freight forwarding service fees paid by export enterprises, etc.).

　　(3) Documents for export enterprises entrusting other entities to declare customs (including: customs declaration entrustment agreements, agency customs declaration service fee invoices issued to them by the entrusted customs declaration entity, etc.).

　　(4) For export enterprises, sales accounting vouchers, sales subsidiary ledgers, and other materials that can corroborate that the goods have been sold (hereinafter referred to as sales corroborating materials).

　　It should be noted that: if a taxpayer cannot obtain an export contract for an overseas warehouse business, it may choose to use overseas warehouse booking forms, ownership documents of self-operated overseas warehouses, overseas warehouse lease agreements, or other relevant materials that can corroborate the use of the overseas warehouse for document filing. If a taxpayer cannot obtain other documents, other materials with similar content or function may be used for document filing.

　　Eight, for goods exported by taxpayers through overseas warehouses, is it necessary to submit sales supporting materials when filing for export tax rebate (exemption)?

　　When a taxpayer files for export tax refund (exemption), there is no need to submit sales supporting materials. According to the Announcement, where a taxpayer files for export advance tax refund under the "refund upon departure, settlement upon sales" method, it shall complete the retention of sales supporting materials within 15 days after the goods are sold, for verification by the tax authority; where a taxpayer files for export tax refund (exemption) under current regulations, it shall complete the retention of sales supporting materials within 15 days after filing for export tax refund (exemption), for verification by the tax authority.

　　IX. If a taxpayer applying for export advance tax refund fails to retain sales supporting documentation as required, how should it be handled?

　　Where a taxpayer fails to retain sales supporting materials as required, it shall be handled as the taxpayer's failure to file documents as required, that is: in accordance with Article 5, Item (8) of the Announcement of the State Taxation Administration on Issues Concerning the Measures for the Administration of VAT and Consumption Tax on Export Goods and Labor Services (2013 No. 12), the export business no longer applies the export refund (exemption) policy and instead applies the exemption policy. If the refund (exemption) has already been declared, a negative declaration shall be used to offset the original declaration.

　　10. For export overseas warehouse business for which the taxpayer has already declared and received an advance export tax refund, if the tax authority finds during verification that the sales supporting materials retained by the taxpayer are forged or false, how should it be handled?

　　According to the Announcement, for export overseas warehouse business for which the taxpayer declares export advance tax refund, sales supporting materials shall be retained as export tax refund (exemption) filing documents for inspection. If verification finds that the sales supporting materials retained by the taxpayer are forged or false, the tax authority shall handle it as the taxpayer providing false filing documents, that is: according to Article 7(1) of the Notice of the Ministry of Finance and the State Taxation Administration on the VAT and Consumption Tax Policies for Export Goods, Labor Services (Cai Shui [2012] No. 39), and Article 5(9) of the Announcement of the State Taxation Administration on Issues Concerning the Measures for the Administration of VAT and Consumption Tax on Export Goods, Labor Services (No. 12 of 2013), this export business shall no longer apply the export tax refund (exemption) policy and shall instead apply the taxation policy. If it is verified to be tax evasion or fraud, it shall be handled according to the corresponding provisions.

　　11. For goods exported by taxpayers through the export overseas warehouse method, is it necessary to submit foreign exchange collection materials when declaring and handling export tax refund (exemption)?

　　For exports by taxpayers via overseas warehouses, when filing for export tax refund (exemption), unless there are special circumstances specified in Article 8, Paragraph (2), Items 1 to 3 of the Announcement of the State Taxation Administration on Matters Concerning Further Facilitating Export Tax Refund Processing and Promoting the Steady Development of Foreign Trade (No. 9 of 2022), no foreign exchange collection materials need to be submitted.

　　12. For goods exported by taxpayers before the Announcement takes effect, can the "tax refund upon departure" policy be applied?

　　The Announcement takes effect on January 27, 2025. Goods exported by taxpayers via overseas warehouses before the Announcement takes effect but for which export tax refund (exemption) has not yet been filed shall all be filed for export tax refund (exemption) in accordance with the "refund upon departure" method.

　　Illustration: A certain export enterprise exports goods by means of overseas warehouses. The export date stated on the export goods declaration form issued by customs is December 20, 2024. As of January 27, 2025 (i.e., the date the Announcement came into effect), the enterprise had not yet filed an export tax refund (exemption) declaration for this export goods. When the enterprise files the export tax refund (exemption) on February 20, 2025, it shall handle it according to the "tax refund upon departure" method. In the specific filing, for goods that have already been sold, the enterprise shall file and handle the export tax refund (exemption) according to current regulations; for goods that have not yet been sold, the enterprise shall, according to the "tax refund upon departure, recalculation upon sale" method, first file an export advance tax refund, and later conduct tax calculation based on the actual sales situation.

　　To thoroughly implement the decisions and arrangements of the Party Central Committee and the State Council and support the development of new business forms and models such as cross-border e-commerce export overseas warehouses, the State Taxation Administration has decided to implement for taxpayers exporting goods by way of cross-border e-commerce export overseas warehouses (hereinafter referred to as export overseas warehouses)"tax refund upon departure". The relevant export tax refund (exemption) matters are hereby announced as follows:

　　I. If a taxpayer exports by means of an overseas warehouse (customs supervision method code“9810", the same below) exported goods, after the goods are declared and leave the country, the taxpayer may file for export tax refund (exemption). When filing for export tax refund (exemption), if the goods have already been sold, the taxpayer shall file in accordance with current regulations; if the goods have not yet been sold, the taxpayer shall file in accordance with the "refund upon departure, accounting upon sale" method, that is: after the goods are declared and leave the country, the taxpayer may file in advance for export tax refund (exemption) (hereinafter referred to as export advance tax refund), and subsequently conduct tax accounting based on the goods' sales situation.

　　II. Taxpayers shall, on the strength of the export goods customs declaration form and relevant material information, file with the competent tax authority to handle export advance tax refund, and shall file in accordance with the following requirements:

　　(1) In the declaration detail form In the "Refund (Exemption) Business Type" column, fill in the "overseas warehouse pre-refund" identifier (business type code:HWC-YT）。

　　(2) Distinguish between goods for which sales have not been realized and goods for which sales have been realized, and file export pre-refund applications and export refund (exemption) applications respectively; if no distinction is made, the goods shall all be deemed as having unrealized sales, and export pre-refund applications shall be filed uniformly.

　　If goods under the same item number on the export goods customs declaration are not all sold, the taxpayer may file separately as per the above provisions, or treat all goods under that item number as unsold and uniformly file for export advance tax refund.

　　(3) Production enterprises shall use a separate declaration sequence number, and foreign trade enterprises shall use a separate association number to declare export advance tax refunds.

　　III. Taxpayers that have declared and handled export advance tax refund shall handle export advance tax refund accounting within each VAT tax declaration period before the deadline of the accounting period. With the consent of the competent tax authority, foreign trade enterprises may also handle export advance tax refund accounting at other times outside the VAT tax declaration period before the deadline of the accounting period. The above accounting period refers to the month following the completion of export advance tax refund by the tax authority 1 From the day to the following year4Month30Day.

　　Where a taxpayer fails to process the accounting before the deadline of the accounting period, the tax authority shall recover the export advance tax refund already processed; after the goods are sold, the taxpayer shall declare and process the export refund (exemption) in accordance with current regulations.

　　IV. When handling export advance tax refund accounting, taxpayers shall, based on actual sales conditions, distinguish the following different situations for processing:

　　(1) If the goods have already been sold at the time of accounting, the difference between the refund (exemption) amount calculated according to the actual sales situation and the export advance refund amount shall be confirmed. If no difference exists, the taxpayer confirms"no adjustment to the filing required", and the accounting procedures are completed; if there are discrepancies, the taxpayer confirms "adjustment to the filing required" and, after adjusting the filing, the accounting procedures are completed.

　　(II) If the goods have still not been sold at the time of accounting, the taxpayer confirms After "tax filing adjustment required" and full repayment of the export advance tax refund, the accounting procedures are completed. Subsequently, once the goods are sold, the taxpayer may re-file for export tax refund (exemption) in accordance with current regulations.

　　The specific operation method for the above adjustment declaration and repayment of export advance tax refund is: when filing export tax refund (exemption) for the accounting period, the taxpayer shall first offset the previous export advance tax refund declaration data in full with a negative amount, and then re-declare the export tax refund (exemption) according to current regulations based on the actual sales situation of the goods. In the accounting period, if the taxpayer's refundable (exemptible) tax amount is negative, production enterprises shall carry it forward to the next period for continued offset, and foreign trade enterprises shall repay the tax; if the refundable (exemptible) tax amount is positive, the tax authorities shall handle the export tax refund (exemption) according to current regulations.

　　V. Taxpayers that have filed for export advance tax refund but have not yet completed accounting shall first complete the export advance tax refund accounting if they need to change the tax refund (exemption) method or withdraw the export tax refund (exemption) filing. After the accounting procedures are completed and the export tax refund (exemption) amount is settled, the tax authority shall handle it in accordance with current regulations.

　　VI. Where a taxpayer exports goods via overseas warehouses, in addition to filing documents in accordance with the current export tax refund (exemption) filing document management regulations, the following provisions shall also be followed:

　　(1) If an export contract cannot be obtained, the taxpayer may choose to use overseas warehouse booking forms, ownership documents of self-operated overseas warehouses, overseas warehouse lease agreements, or other relevant materials that can corroborate the use of overseas warehouses for document filing.

　　(II) Taxpayers shall treat sales accounting vouchers, sales subsidiary ledgers, and other materials that can corroborate that the goods have been sold (hereinafter referred to as sales corroborating materials) as export tax refund (exemption) filing documents. Where a taxpayer applies for and handles export advance tax refund, after the goods are sold 15 Within days, complete the retention of sales supporting documentation for tax authority verification; those filing for export tax refund (exemption) in accordance with current regulations shall, after filing for export tax refund (exemption),15Within days, complete the retention of sales supporting documentation for tax authority verification.

　　Taxpayers may choose paper, image, or digital methods to retain and keep the above filing documents.

　　VII. Taxpayers shall truthfully declare and handle export advance tax refund and accounting in accordance with the law. Tax authorities shall review and handle export advance tax refund and accounting in accordance with current provisions; where any suspicious point such as suspected export tax fraud is found, they shall handle it only after verification and elimination of the suspicious point. When conducting verification, tax authorities shall also verify the actual sales situation; where it is found that sales supporting materials are not retained as required or are forged or false, the refunded (exempted) tax shall be recovered and handled in accordance with current provisions; where export tax fraud is verified, it shall be handled in accordance with "Tax Collection and Administration Law of the People's Republic of China" and relevant provisions.

　　Eight, matters not covered in this announcement shall be handled in accordance with current export tax rebate (exemption) regulations.

　　IX. This announcement shall take effect from the date of publication. Before this announcement takes effect, if a taxpayer exports goods via overseas warehouses but has not yet declared export tax refund (exemption), this announcement shall apply.

　　Hereby announced.

State Taxation Administration

2025 Year1Month 27