Do agency export service fees require VAT payment? How are advance payments taxed?

1. Is value-added tax (VAT) required for agency export service fees?

According to the current VAT policy in 2025, agency export service fees fall underModern Services - Business Support ServicesCategories, to be classified by6% tax ratePay value-added tax. However, please note the following special circumstances:

• If the service recipient is an overseas entity and the consumption occurs entirely outside the country, the cross-border service tax exemption policy may apply.
• When an agency provides mixed services such as customs clearance and logistics, it must account for each business type separately.

2. Advance PaymentMaritime TransportationDo customs declaration fees and clearance fees need to be taxed?

The advance payment made by the agency companyReimbursement of actual expensesIncome that meets the following conditions may be excluded from taxable income:

• Please provide the original payment and receipt voucher or a copy with the official seal affixed.
• Clearly stipulate the collection and payment agency terms in the contract.
• The fund flow corresponds one-to-one with the business documents.

Common risk points in practice:

• Failure to account separately resulting in being deemed as an additional charge.
• Advance funds received interest undeclared value-added tax

III.Export DrawbackHow to handle tax treatment for installment payments?

In the agency export business, the tax refund sharing involves dual tax treatments:

• Regarding value-added tax (VAT): The tax refund itself is not subject to VAT, but the profit-sharing agreement needs to be distinguished by nature.
  • If it is a service consideration, value-added tax shall be calculated and paid at a rate of 6%.
  • If it is a profit distribution, it does not involve value-added tax.
• Corporate income tax matters: Regardless of its nature, it shall be included in taxable income.

4. What tax issues are involved in cross-border payment service fees?

When paying agency service fees to overseas entities, special attention should be paid to:

• Withholding and remitting6% VAT(If tax exemption is not applicable)
• Withholding and remitting10% Corporate Income Tax(unless tax treaty benefits apply)
• Filing requirements: Tax filing is required for single transactions exceeding USD 50,000.

Special Reminder: The 2025 revised version of the "Tax Treaty" has updated the criteria for determining permanent establishments. It is recommended to conduct a tax treaty benefit analysis before making payments.

V. How to Standardize Tax Management for Agency Export Business?

Recommended for enterprises to establishThree core mechanisms:

• Contract Terms Review Mechanism
  • Clarify the pricing method of service fees
  • Agreement on the Provision of Instruments
• Integration of "Business Flow, Capital Flow, and Document Flow" for Management Control
• Regular tax health check system (recommended quarterly)

Typical Case: A company incurred losses exceeding 2 million yuan due to overpayment of 13% value-added tax on goods by combining agency fees with goods value in invoicing.