Must the Export Invoice Be Issued by the Agency Company for Agency Exports?

Must the Export Invoice Be Issued by the Agency Company for Agency Exports?

The declared entity of the customs declaration formThe declared entityandExport DrawbackThe matching relationship. According to the current regulations in China:When using

• A double - headed customs declaration form(Manufacturer + Agent):The manufacturing enterprise can issue a VAT ordinary invoice to the agency company by itself
  • The agency company applies for tax refund based on the customs declaration form and the purchase invoice
  • If a single - headed customs declaration is adopted
• If adoptingSingle - header Customs Declaration(Only display the agency company):
  • The manufacturing enterprise must issue a special VAT invoice to the agency company.
  • The agency company, as the main body for tax refund declaration, shall bear legal responsibilities.

What should be done if the amount on the export invoice is inconsistent with the declared amount for customs?

In 2025, the General Administration of Customs strengthenedthe trade authenticity verification system, and false invoices will trigger the following risks:

• Administrative penalty: A fine of 10% - 50% of the value of the goods.
• Credit downgrading: The customs credit rating is downgraded to Class D.
• Criminal liability: If the amount of tax fraud involved exceeds 500,000 yuan, a prison term of 3 - 10 years may be faced.

It is recommended that enterprisesverify the authenticity of the invoices provided by the agency company through the invoice verification platform of the Electronic Tax Bureau, and keep complete logistics documents as evidence.According to the latest version of the Measures for the Administration of VAT on Exported Goods and Labor Services in 2025, the existence of

How can cross - border e - commerce avoid the risks of agency invoice issuing?

a reasonable range of differencesis allowed. For exchange rate fluctuations: Use the spot exchange buying rate of the Bank of China on the invoice issuing date for conversion.:

• For freight allocation: The price difference between CIF and FOB shall be attached with a transportation contract.
• For quality deductions: A quality objection letter signed and recognized by the customer shall be provided.
• When the difference range exceeds ±5%, a

special matter descriptionshall be submitted to the competent tax authority, and the following documents shall be provided:A supplementary agreement confirmed by both the buyer and the seller

• A bank statement of international settlement
• A third - party inspection report (if involving quality disputes)
• How to avoid the risk of agency invoicing?

Cross-border E-commerceIn response to the new policies of the cross - border e - commerce comprehensive pilot zones in 2025, it is recommended to adopt the following

compliance management measuresClear contract terms::

• Specify the invoice type (proforma invoice/commercial invoice/customs invoice)
  • Determine the currency conversion rules
  • System connection guarantee:
• Directly connect the data of the ERP and the agency companys invoicing system
  • Set an automatic early - warning threshold for the invoicing amount
  • Regular compliance audits:
• Check the customs declaration forms and invoice lists monthly
  • Sample - check the original vouchers quarterly
  • It is recommended to conduct

In the latest international trade practice in 2025, the issuing entity of the export invoice depends on

qualification verificationthrough the following channels. Tax system verification::

• Log in to the National VAT Invoice Verification Platform to check the invoice code
  • Check the classification management level of the agency companys export tax refund (it needs to reach Class II or above)
  • Customs filing query:
• Verify the validity of the Registration Certificate of the Declarant on the website of the General Administration of Customs
  • Confirm the AEO certification status (it is recommended to choose an advanced certified enterprise)
  • Commercial credit report:
• Obtain a credit investigation report issued by a third - party institution
  • Focus on checking the tax - related litigation records in the past three years
  • (The rules described in this article are based on the Opinions on Comprehensively Deepening the Regulatory Reform of Comprehensive Service Enterprises and its supporting implementation rules that came into effect in January 2025. For specific operations, please refer to the latest interpretation of the competent authorities.)

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