I. Who should issue the export invoice for an agency company?

According to the latest 2025 "Administrative Measures for Value-Added Tax on Cross-border Taxable Acts," there are two invoicing models for export agency business:

• Self-operated export model: The agency company issues the invoice as the seller and needs to bear the cargo ownership risk
• Pure agency mode: The actual supplier directly invoices the overseas buyer, and the agency company charges a service fee

We recommend that the invoicing party be clearly specified in the contract, and that a complete set ofagency agreements, customs declarations, and?Forex Settlement?Voucherbe kept as a basis for tax inspection.

II. Must the invoice header show the agency company's name?

According to international trade practices and tax compliance requirements:

• Regular agency business: The seller on the invoice should show the full name and tax number of the agency company
• dual-header customs declaration: It can be noted as "Agent: XXX Company" with the principal's information attached
• Special customs supervision zones: The actual cargo owner's information must be shown as required by customs supervision

In 2025, many local tax bureaus will promote theblockchain invoice verification system. It is recommended to confirm the accuracy of the invoicing information with the agency company in advance.

III. How to write the product name and HS code on the export invoice?

Three matching principles must be strictly followed:

• Consistent with the contract and the actual goods
• Consistent with the customs declaration information
• Consistent with the foreign exchange collection voucher description

Special reminder: From 2025, some commodities (such as lithium batteries, medical equipment) will require special identifiers such as theUN number andMedical Devicesregistration certificate numberto be noted in the invoice remarks column.

IV. Can tax-free invoices be issued for export agency?

According to Announcement No. 1 of 2025 by the Ministry of Finance, a tax-free invoice can be issued if the following conditions are met simultaneously:

• Goods actually depart the country and completeExport Clearance
• The source of foreign exchange collection is an overseas account
• The agency company has the qualification of aforeign tradetrade operator
• Obtain the export customs declaration form issued by the customs.

Note:Cross-border E-commerceRetail exports require providing apayment institution's collection voucheras a basis for tax exemption.

V. What to do if the invoice amount is inconsistent with the declared amount?

This is a high-risk point that can trigger a customs audit. It is recommended to take the following measures:

• Reasonable error within 10%: Provide a breakdown of freight/insurance to explain the difference
• Difference of more than 10%: A customs declaration amendment procedure must be carried out
• Exchange rate fluctuation factor: Specify exchange rate adjustment clauses in the contract

Typical case: A company was pursued for back taxes and fined 580,000 yuan by customs for under-reporting the invoice amount by 20%.

VI. Can electronic invoices be used forTax RebatesAccording to Document No. 38 of the State Administration of Foreign Exchange in 2025,

Since September 2024, the State Administration of Taxation has fully implemented thedigitalized electronic invoice (fully electronic invoice), whose legal effect is equivalent to that of a paper invoice. However, it should be noted that:

• It must be issued through the tax bureau's platform
• The invoice remarks column must be marked with "Export Business"
• The source file in XML format must be kept for future reference

VII. How to avoid compliance risks with export agency invoices?

It is recommended to establish a three-tier review mechanism:

• Formal Review: Check the completeness of the basic information on the invoice
• Substantive review: Verify the authenticity of the business (contract-logistics-capital flow)
• Special review: Conduct a special verification for sensitive goods

Important note: In 2025, the General Administration of Customs will includeinvoice informationas a key monitoring dimension in the "Smart Audit" system.

VIII. What are the consequences for an agency company that issues false invoices?

According to Article 205 of the Criminal Law, involvement in issuing false invoices will face:

• A fine for the unit (1-5 times the amount involved)
• A sentence of 2-7 years in prison for the person responsible
• Being blacklisted by customs
• Cancellation of the export tax rebate qualification

Protection suggestion: Regularly check for anomalies through the e-Tax Bureau'sinvoice flow queryfunction.

IX. How to issue invoices for multi-country trade transit?

For complex trade involving transit through a third country, it is recommended to use:

• A split invoice system: Issue invoices in segments according to the actual transaction links
• Transit warehouse filing: Note the transit warehouse code in the invoice remarks
• Certificate of tax residence: To avoid double taxation

Special reminder: For transit through ASEAN countries, aFORM EOrigin Certificatecopy must be provided as an invoice attachment.

X. How to choose a compliant agency invoicing company?

Recommend evaluating agency qualifications from these dimensions:

• Whether it has a Class A customs brokerage enterprise qualification
• Whether it is connected to the international trade "Single Window" system
• Whether it has a complete compliance risk control system
• Whether it is equipped with a professional foreign trade documentation team

We recommend conducting atrade compliance auditof the agency company at least quarterly to ensure the business chain is legal and compliant.