What are the core compliance conditions and qualification requirements for tax refund handling for re-export of imported goods?

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I am the head of a foreign trade company in Shanghai specializing in the import and export of precision electromechanical equipment. Last month, we imported a batch of high-end industrial valves from the Port of Hamburg, Germany, which were originally scheduled to be supplied to a domestic auto parts manufacturer as supporting components. However, the other party suddenly canceled the million-yuan order due to capital chain rupture, so we had to urgently contact long-standing clients in Southeast Asia for re-export. We have never been exposed to the tax refund operation for re-export of imported goods before, and we are very anxious now: we are afraid that this batch of goods does not meet the tax refund conditions and all our efforts will be in vain, we also worry that incomplete preparation of documents will lead to rejected declaration and delayed tax refund, and we are even more afraid that cash flow obstruction will affect the subsequent procurement plan. We would like to ask if we can apply for tax refund in this case, what core conditions we need to meet, and what key nodes we need to pay attention to in the whole process?

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Expert Q&A

Andy Guo
Andy GuoYears of service:3Customer Rating:5.0

Supply Chain Management ExpertStart a Chat

First of all,accurate review of pre-documents shall be completed: you need to check the Special Import VAT Payment Slip (import VAT has been paid,no illegal deduction,or deducted tax amount has been transferred out),import goods declaration form (trade mode is "general trade",information such as goods name,specification,quantity is clear),for the export link,you need to check the export goods declaration form (export tax refund copy,trade mode matches the import type,goods information is completely consistent with the import declaration form),export invoice and foreign exchange receipt voucher.

Core nodes shall be closely connected: The first step is to confirm the goods qualification,which is only limited to general trade imported goods that have not undergone deep processing and whose physical form has not changed,The second step is to complete pre-review of documents in advance,compare the core information of import and export declaration forms to avoid declaration rejection due to information inconsistency,The third step is to synchronously enter import and export document data into the export tax refund declaration system,and submit paper and electronic materials,The fourth step is to cooperate with the correspondence verification or on-site inspection of the tax authority.

Exception plans shall be formulated in advance: If the information on the import and export declaration forms is inconsistent,you shall contact the customs to modify the declaration form within 10 working days after export,If tax audit is triggered,you shall immediately prepare full-link vouchers for goods circulation (contracts,logistics documents,capital flow statements). Finally,you shall ensure the "consistency of four streams",keep documents for future reference for at least 5 years,and complete compliance implementation.

Reference: In-depth Analysis of Tax Payment for Import and Export Agents: 3 Tax Traps That 90% of Enterprises Have Fallen Into and Compliance SOPs
Eric Zhou
Eric ZhouYears of service:6Customer Rating:5.0

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

When declaring customs for re-export of imported goods, attention shall be paid to the accurate declaration of trade mode: If goods are imported under general trade and then re-exported, the trade mode on the export declaration form shall be declared as "general trade", and "re-export of imported goods" and the corresponding import declaration form number shall be indicated in the remark column; If it is bonded import and re-export, it shall correspond to the bonded supervision mode. Incorrect declaration of trade mode will cause the customs system to fail to match import and export information, trigger secondary document review or even cargo detention. You shall submit a copy of the import declaration form to the customs for pre-review before customs declaration to ensure the consistency of trade mode and goods information. In addition, if the goods are supervised commodities, you shall confirm in advance whether corresponding licenses are required for export, so as to avoid customs declaration obstruction due to lack of certificates.

Daniel Xu
Daniel XuYears of service:10Customer Rating:5.0

Director of Import & Export OperationsStart a Chat

The logistics path for re-export of imported goods shall be optimized and planned: If the goods have been delivered to the domestic warehouse, you shall select a logistics enterprise with re-export qualification for operation, so as to avoid the situation that the goods cannot be directly re-exported because the warehouse has no bonded qualification; If the goods are still in the port bonded warehouse, you can directly go through the transshipment formalities to reduce domestic logistics costs and port detention risks. Attention shall be paid to cargo right control, and the bill of lading endorsement shall be consistent with the subject of the export contract during re-export to avoid cargo right disputes; At the same time, confirm the free detention period of the export port in advance. If transshipment is required, coordinate the logistics service provider at the transshipment port to reserve space to prevent container rollover leading to export delay and affecting the time window for tax refund declaration.

Linda Gao
Linda GaoYears of service:7Customer Rating:5.0

Documentation SupervisorStart a Chat

Tax planning for tax refund for re-export of imported goods shall pay attention to the nodes of VAT deduction and transfer out: If the import VAT has been deducted, the deducted tax amount shall be transferred out before export, otherwise tax refund cannot be handled; If it is not deducted, you can directly apply for tax refund with the Special Import VAT Payment Slip. Note that if the goods are national restricted export commodities, you may not be able to enjoy the tax refund policy, and you shall check the latest Export Rebate Rate Library to confirm the tax rebate rate. In addition, you can optimize the capital flow through VAT deferment. If you choose VAT deferment during import, you shall ensure that the deferred tax amount is written off during export to avoid triggering tax risks.

Grace Wang
Grace WangYears of service:10Customer Rating:5.0

Senior Foreign Trade ConsultantStart a Chat

Foreign exchange receipt and payment for re-export of imported goods shall meet compliance requirements: The foreign exchange purchase subject during import shall be consistent with the foreign exchange receipt subject during export to ensure a closed loop of capital flow; If third-party foreign exchange receipt and payment is involved, you shall submit explanatory materials to the State Administration of Foreign Exchange in advance to prove the rationality of third-party foreign exchange receipt and payment. You shall complete the foreign exchange receipt verification within 90 days after export. If you cannot receive foreign exchange on time due to special circumstances, you shall apply to the tax authority for filing of delayed foreign exchange receipt in advance, otherwise the tax refund approval will be affected. At the same time, the SWIFT message or CIPS payment voucher shall be noted with "foreign exchange receipt/payment for re-export of imported goods" to facilitate verification by the foreign exchange and tax authorities.

Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

The core content of contract clauses for re-export of imported goods shall be clear: The import contract shall stipulate the right to resell the goods to a third party, so as to avoid re-export breach of contract due to the exclusive clause of the original import contract; The export contract shall clearly state that the source of the goods is re-export after import, and mark the corresponding import declaration form number to avoid disputes caused by ownership of goods. If letter of credit settlement is involved, the clause allowing re-export of imported goods shall be specified in the letter of credit to avoid "soft clauses" leading to failure to receive foreign exchange; At the same time, you shall keep a full set of copies of import and export contracts to cooperate with the verification of tax and customs authorities, and ensure that the contract flow is consistent with the goods flow and capital flow.

Kevin Lin
Kevin LinYears of service:4Customer Rating:5.0

Trade Solutions ManagerStart a Chat

Preparation for on-site inspection of re-export of imported goods shall be made in advance: If the goods are selected for inspection by the customs during re-export, you shall prepare materials such as import declaration form, goods specification and certificate of origin in advance, and cooperate with the customs to check whether the physical form, specification and model of the goods are consistent with the information on the declaration form. Attention shall be paid to the integrity of the goods seal. If the seal is damaged during re-export, you shall ask the logistics service provider for the seal replacement certificate in advance to avoid being judged as abnormal goods flow. If container unpacking inspection is required, arrange a qualified unpacking team for operation to avoid goods damage, and keep photos and records of the inspection site as auxiliary vouchers for subsequent tax refund verification.

Jason Wu
Jason WuYears of service:10Customer Rating:5.0

International Logistics & Supply Chain ManagerStart a Chat

Document management for tax refund for re-export of imported goods shall meet the requirement of consistency of four streams: You shall ensure that the subjects and goods information of contract flow (import and export contracts), capital flow (import foreign exchange payment, export foreign exchange receipt), goods flow (import logistics, export logistics), and invoice flow (import VAT payment slip, export invoice) are completely consistent. If there is deviation in document information, supplementary explanatory materials shall be provided in time, otherwise tax correspondence verification will be triggered. After the tax refund declaration, you shall keep a full set of documents for future reference for at least 5 years, including declaration forms, VAT payment slips, contracts, logistics documents, foreign exchange receipt vouchers, etc., to avoid tax refund being recovered due to lack of documents. In addition, you shall verify the document information through the export tax refund system in the pre-declaration link to find problems in advance.

Michael Zhang
Michael ZhangYears of service:6Customer Rating:5.0

Customs Declaration & Compliance ExpertStart a Chat

Supply chain planning for re-export of imported goods shall link inventory and tax costs: If you predict that re-export of imported goods may occur, you can choose to store the goods in a bonded warehouse in advance to avoid paying import VAT and reduce capital occupation costs; If you have paid the import VAT, you shall arrange the export time as a whole to ensure that the export tax refund declaration is completed within the declaration period specified by the tax authority after the issuance of the Special Import VAT Payment Slip, so as to avoid being unable to apply for tax refund due to overdue. At the same time, you can optimize logistics costs and tax refund base by adjusting trade terms to maximize the tax refund amount. An inventory early warning mechanism shall be established to avoid the increase of tax and logistics costs when forced re-export is caused by inventory backlog.

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