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State Taxation Administration

Announcement on Matters Relating to Supporting the Development of Cross-Border E-Commerce Export Warehouses Abroad and the Refund (Exemption) of Export Taxes

State Taxation Administration Announcement No. 3 of 2025

　　To thoroughly implement the decisions and arrangements of the CPC Central Committee and the State Council, and to 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 the policy of “tax refund upon departure” for goods exported by taxpayers through cross-border e-commerce export overseas warehouses (hereinafter referred to as “export overseas warehouses”). The relevant matters concerning export tax refund (exemption) are hereby announced as follows:

• If the goods have already been sold when the refund is claimed, the taxpayer shall apply for the export tax refund (exemption) in accordance with the current rules.
• If the goods have not yet been sold, the taxpayer shall apply under the “refund upon departure, reconciliation after sale” approach, i.e., file a preliminary export tax refund (exemption) application (hereinafter “export pre-refund”) after customs clearance and departure, and subsequently reconcile the tax amount based on the actual sale of the goods.

　　II. To obtain the export pre-refund, taxpayers must submit the export customs declaration and other relevant documents to the competent tax authority, and shall observe the following     requirements:

　　  (1) In the "Type of Refund (Exemption) Business" column of the declaration schedule, enter the label "Overseas-warehouse Pre-refund" (business-type code: HWC-YT).

         (2) Separate the goods that have not yet been sold from those that have already been sold and file the export pre-refund declaration and the normal export refund (exemption)declaration accordingly.

 If no separation is made, all goods are treated as unsold and a single export pre-refund declaration is filed.

If, under the same item number on the export customs declaration, only part of the goods have been sold, the taxpayer may either separate them as described above or treat 

the entire item as unsold and file a single export pre-refund declaration.

        (3) Manufacturing enterprises must use a separate declaration serial number, and foreign-trade enterprises must use a separate association number when declaring the exportpre-refund.

　　III. Taxpayers who have applied for the export pre-refund must complete the reconciliation of that pre-refund during each VAT-filing period that falls before the reconciliation deadline. With the approval of the competent tax authority, foreign-trade enterprises may also reconcile outside the regular VAT-filing periods, provided they do so before the reconciliation deadline.

　　If a taxpayer fails to complete the reconciliation before the deadline, the tax authority shall recover the pre-refund already granted; once the goods are subsequently sold, the taxpayer may file for an export tax refund (exemption) anew in accordance with the current rules.

　    IV. When conducting the reconciliation of an export pre-refund, taxpayers must handle it in accordance with the actual sales situation, as follows:

　　    (1) If the goods have been sold at the time of reconciliation, the taxpayer shall compare the refund (exemption) amount calculated based on the actual sales with the amount already pre-refunded.

• If no difference exists, the taxpayer selects “No adjustment required” and completes the reconciliation.
• If a difference exists, the taxpayer selects “Adjustment required”, submits an adjustment declaration, and then completes the reconciliation.

• Once the goods are sold later, the taxpayer may re-apply for export tax refund (exemption) under the current rules.

1. First fully reverse the previous pre-refund declaration using a negative entry;
2. Then re-declare the export tax refund (exemption) based on the actual sales situation under current rules.

• If the refund (exemption) amount for the reconciliation period is negative:
  • Manufacturing enterprises: carry forward the excess to the next period for continued offset;
  • Foreign-trade enterprises: must repay the tax.
• If the refund (exemption) amount is positive, the tax authority will process the export tax refund (exemption) under the current rules.

　　V. Taxpayers who have applied for export pre-refund but have not yet completed reconciliation and who wish to change their refund (exemption) method or withdraw their export refund (exemption) registration must first complete the reconciliation of the export pre-refund. Only after the reconciliation formalities are finalized and all export refund (exemption) amounts have been settled will the tax authority proceed with the requested change or withdrawal in accordance with the current rules.

　　                                                 　　VI. For goods exported under the export overseas warehouse method, in addition to filing documents in accordance with the current administration rules on archiving documents for 

export tax refund (exemption) filing, taxpayers must also comply with the following:

            1. If an export contract cannot be obtained, taxpayers may choose to file documents such as the overseas warehouse booking note, documents evidencing ownership of a

 self-operated overseas warehouse, an overseas warehouse lease agreement, or any other relevant materials that can substantiate the use of the overseas warehouse.

            2. Taxpayers shall treat accounting vouchers for sales, sales subsidiary ledgers, and any other materials that can evidence the goods have been sold (hereinafter referred to as 

“sales supporting documents”) as the documents to be filed for export tax refund (exemption).  

   - Where a taxpayer applies for export pre-refund, the sales supporting documents must be retained within 15 days after the goods are sold for possible inspection by the tax authority.  

   - Where a taxpayer applies for export tax refund (exemption) under the current rules, the sales supporting documents must be retained within 15 days after the refund (exemption) application

 is submitted for possible inspection by the tax authority.

Taxpayers may, at their own discretion, retain the above-mentioned filing documents in paper, imaged, or digital form.

　　VII. Taxpayers shall truthfully apply for export pre-refund and its reconciliation in accordance with the law. The tax authorities shall examine and process such applications under the existing rules; where any suspicion of fraudulent refund arises, the formalities will be completed only after the doubts have been removed through verification. During the verification process, the tax authorities shall also check the actual sales situation. If a taxpayer fails to retain the required sales supporting documents as prescribed, or if such documents are found to be forged or false, the refunded (exempted) tax shall be clawed back and the case dealt with under the current provisions; once an act of fraudulently obtaining export tax refunds is established, it shall be handled in accordance with the Law of the People’s Republic of China on the Administration of Tax Collection and other relevant regulations.

　　VIII. Matters not covered by this Announcement shall be handled in accordance with the current provisions on export tax refund (exemption).

        IX. This Announcement shall take effect from the date of its issuance. For goods exported under the export overseas warehouse method before the effective date but for which

 no export tax refund (exemption) has yet been declared, the provisions of this Announcement shall apply.

　　It is hereby announced.

State Taxation Administration

January 27, 2025