Agency export,Who should issue the VAT invoice?

In agency export business, the entity issuing VAT invoices should be determined based onthe substance of the tradeas follows:

• When a manufacturing enterprise entrusts a foreign trade company with agency export:
  • The manufacturing enterprise issues a VAT special invoice to the foreign trade company
  • The remarks column on the invoice must indicate the phrase "agency export."
• Under the comprehensive foreign trade service provider model:
  • The manufacturing enterprise directly issues invoices to the overseas buyer
  • The foreign trade enterprise provides foreign exchange collection and customs declaration documents

How to determine the amount on agency export invoices?

Three key points to note for cross-border trade invoice amount confirmation in 2025:

• TakeCustoms declaration FOB priceUse as the benchmark for RMB amount conversion
• Agency service fees should be issued separately on VAT ordinary invoices
• The exchange rate should use the middle rate on the date of customs declaration issuance

Must the product name on the invoice exactly match the customs declaration form?

In accordance with the requirements of Announcement No. 12 of 2025 from the State Taxation Administration:

• The main product name must exactly match the customs declaration form
• Supplementary information such as specifications and models may be added to the invoice
• HS codes do not need to appear on VAT invoices

What documents are required to apply for tax refund in agency export?

Year 2025Export tax refundThe following core documents must be prepared for declaration:

• Agency export goods certificate with customs seal
• Original VAT special invoice deduction copy
• Bank foreign exchange receipt (cross-border RMB settlement document)
• Customs declaration information downloaded from the electronic port

How should agency service fee invoices be handled?

Foreign trade agency service fee invoice issuance specifications:

• Must be issued separately6% VAT special invoice
• The product name should be clearly stated as "import and export agency services."
• Cannot be mixed with goods sales invoices

How to avoid common invoicing errors?

Based on 2025 audit cases, special attention should be paid to:

• Cross-year invoicing issues:
  • For transactions with export dates in December 2024
  • Latest invoicing deadline must not exceed April 30, 2025
• Customs declaration form and invoice unit conversion errors
• Failure to note agency agreement number in remarks column

Special notice: Starting January 2025, the State Taxation Administration implementsElectronic invoice cross-border mutual recognition platformIt is recommended to prioritize customs-certified agency service providers to ensure the "three flows integration" of documents, goods, and funds, thereby mitigating tax risks.