On October 1, 2025, the State Taxation Administration's Announcement on Optimizing Matters Related to Corporate Income Tax Advance Payment Filing (Announcement No. 17 of 2025) will officially take effect. Article 7 stipulates that enterprises exporting goods through agency arrangements (including market procurement trade and comprehensive foreign trade services) must concurrently submit the basic information and export value details of the actual exporting party during advance tax filing.
Mandatory Requirements
1. Information submitted by the agency enterprise must trace back to the actual domestic production/sales entity, not intermediate links in the agency chain.
2. Required details include the actual principal's legal name, unified social credit code, corresponding customs export declaration number, and export value.
3. Establishes a tripartite regulatory loop integrating tax, customs, and foreign exchange authorities.
Key Affected Industries
Steel Industry: Since China abolished tax rebates for most steel products in 2021, “buyer-paid export” practices have proliferated in steel markets.
Market Procurement Trade: numerous small and medium-sized merchants rely on buying-on-behalf exports.
Cross-Border E-Commerce: Particularly small sellers exporting via B2C models, many of whom lack import-export licenses.
Foreign Trade Service Providers: One-stop trade platforms must adjust business models and strengthen compliance reviews.
Logistics Agencies: Freight forwarders, customs clearance companies, and related entities must reassess operational risks.
Key Affected Groups
Small and Micro Export Enterprises: Temporary exporters and manufacturers lacking import/export qualifications will face direct impacts.
Foreign Trade Agency Firms: Must transition into specialized institutions with information verification and compliance risk management capabilities.
Individual Foreign Trade Entrepreneurs: Including cross-border e-commerce sellers and Taobao store owners—individuals can no longer serve as tax-paying entities for cross-border shipments.
Different-sized enterprises require distinct strategies to address the new regulations.
Small and Medium Sellers:Engage licensed agents and retain full-chain documentation
Obtain import/export operation rights: Enables independent customs declaration.
Select compliant agents: Diligently evaluate agency qualifications to ensure compliance capabilities.
Maintain complete documentation: Including purchase contracts, export invoices, and logistics records to prove ownership and export authenticity.
Growing Sellers: Register a Hong Kong Company and Partner with Foreign Trade Service Providers
Overseas Structure Setup: Consider registering a Hong Kong or offshore company to legally benefit from tax incentives.
Partner with Legitimate Foreign Trade Service Providers: Select foreign trade service enterprises aligned with policy directives.
Business Process Compliance: Thoroughly review operational workflows to ensure regulatory compliance.
Established Sellers: Obtain independent import/export rights and establish a full-chain tax rebate system
Establish a complete export system: Obtain import/export rights and establish standardized financial and customs declaration systems;
Optimize tax structure: Legally benefit from policies such as export tax rebates;
Internal compliance training: Strengthen internal staff training and foster a compliance culture.
Countermeasures for Agency Enterprises
Pre-verification: Establish a qualification review mechanism for clients, requiring submission of business licenses, production permits, and proof of ownership;
Real-time reporting: During advance declaration periods, submit the Summary Report for each customs declaration form;
Post-event retention: Archive and retain commission agreements, review records, logistics documents, and other materials for at least five years.
The foreign trade industry is shifting from pursuing scale expansion to enhancing quality and regulatory compliance.
Post time: Sep-10-2025
