The era of paying for exports is over!

On July 7, 2025, the State Taxation Administration issued Announcement No. 17 of 2025, revising the prepayment declaration form for enterprise income tax. Article 7 has a significant impact on export business. The "buying order for export" model may come to an end. The announcement will take effect on October 1, 2025. 

The article clearly states that enterprises that export goods through agency (including market procurement trade, comprehensive foreign trade services, etc.) must simultaneously submit the basic information and export amount of the actual consignor when making prepayment declarations. If an enterprise fails to accurately report, it will be treated as self-operated and bear the corresponding enterprise income tax that should be declared and paid for the export amount. The actual consignor refers to the entity that actually produces and sells the goods. This indicates that both the customs declaration agency and the actual consignor involved in "buying order for export" must assume the responsibility for enterprise income tax declaration. This is a restrictive clause formulated by the State Taxation Administration to address the chaos of "buying order for export".

Starting from October 1, 2025 (the beginning of the third quarter), when export enterprises declare their quarterly advance payment of enterprise income tax, they will adopt a new tax declaration method and process. The new regulation has revised the "Monthly (Quarterly) Advance Payment Tax Return for Enterprise Income Tax (Type A)" of the People's Republic of China, adding three detailed columns for self-operated export income, entrusted export income, and export agency fee income in the operating income column. This move refines the management of export income and clarifies the basis for confirming income from agency export business. 

This can better utilize the big data comparison of customs, and before the issuance of Announcement No. 17, the old quarterly reports of enterprises with both domestic and export sales could not be effectively monitored. Domestic and export sales income were mixed in the "Operating Income" column, making it difficult for the tax authorities to compare and confirm the accuracy of export income. The new declaration method can prevent the omission or underreporting of income. The issuance of Announcement No. 17 reminds export enterprises that the state is strengthening the supervision of export enterprises and requires them to comply with policies, operations, and declarations. After the export of goods (including cross-border e-commerce and express export), income must be declared accurately and promptly. For agency exports, the income should be confirmed by the real consignor. For "buying orders", the income should also be confirmed by the real consignor. If the tax authorities find that the agent does not know or is unwilling to provide the real consignor, the agent will become the subject of tax supplementation. False exports, buying order exports, underreporting of goods value, and failure to confirm income on time will be resolutely cracked down on.

The tax authorities will list the following types of enterprises with abnormal export income comparisons as high-risk: enterprises engaged in buying order exports; agency export enterprises undertaking "buying order business", including supply chain, foreign trade comprehensive service, foreign trade, and logistics companies; enterprises with suppliers not issuing invoices on time, delayed confirmation of income from customs declarations, inability to declare income in the same month as export (confirming income based on accounting or receipt of payment time), enterprises with special customs declaration trade methods (such as sample and advertising goods business), and enterprises not confirming export income based on FOB prices. After the issuance of Announcement No. 17, the space for export enterprises to operate in violation of regulations has shrunk, and the tolerance rate has decreased. Relevant departments of enterprises need to pay attention to the business changes brought about by the new document, change their subjective cognition, and realize that the previous marginal operations will no longer work. It is recommended that export enterprises establish a risk awareness, eliminate illegal behaviors such as "buying order exports" and false exports, standardize their own operations, and achieve compliance in trade and taxation.