I. Who should actually issue the invoice for an export agency, the factory or the?Foreign trade?company?

In the export agency business,the VAT special invoice must be issued by the actual supplier of the goods. According to the latest 2025 "Administrative Measures for Value-Added Tax on Exported Goods and Services":

• When a manufacturing enterprise exports through an agent, it needs to issue a VAT invoice with the product name as the exported goods
• When a comprehensive foreign trade service enterprise acts as an export agent, it must obtain a VAT special invoice from the manufacturing enterprise
• The invoice remarks column must be marked with the words "Export Agency" and the customs declaration number

Typical case: A certain ceramic enterprise entrusted a foreign trade company to act as an export agent, but the foreign trade company directly issued an invoice to the overseas client, which resulted in being unable to handle the?Tax Refund?, with a loss of 1.2 million yuan.

II. What invoice documents need to be prepared for export agency?

A complete export agency invoice chain should include:

• Basic invoices:
  • A 13% VAT special invoice from the manufacturing enterprise to the agent
  • A Commercial Invoice from the agent to the overseas client
• Supporting vouchers:
• A power of attorney for customs declaration (the agency relationship must be specified)
• Foreign Exchange?Forex Settlement?A slip (must be consistent with the agency agreement)
• Logistics receipt documents (must match the bill of lading information)

III. What invoice clauses must be specified in the agency agreement?

According to the big data analysis of international trade disputes in 2025, it is recommended to specify in the agreement:

• The time node for issuing the invoice (before shipment/after receiving payment)
• The method for converting the currency exchange rate (it is recommended to use the Bank of China's spot buying rate)
• Dispute resolution clause (especially for the difference between the proforma invoice and the VAT invoice amount)
• The division of responsibility for tax filing (which party is responsible for handling the export tax rebate filing)

IV. Does a proforma invoice (PI) have legal effect?

A Proforma Invoice in an export agency mainly serves as aquotation confirmation, and it should be noted that:

• It cannot replace the tax function of a VAT invoice
• The amount and product name must be consistent with the subsequent official invoice
• It is recommended to add a disclaimer clause "This invoice is not a payment voucher"

Risk warning: A certain machinery export enterprise, due to the trade term (FOB) in the PI being inconsistent with the official invoice (CIF), had the client refuse to pay the final payment, leading to international arbitration.

V. What are the new changes to export agency tax rebates in 2025?

According to Announcement No. 12 of 2025 by the State Administration of Taxation:

• A new "export agency tax rebate filing commitment system" is introduced, shortening the filing period to 3 working days
• A blockchain invoice verification system is launched, requiring the agent to upload an electronic invoice within 72 hours of the goods leaving the country
• Strict investigation of "buying a declaration" behavior. For invoices without a real flow of goods, it will be traced back 5 years from the date of issuance.

Practical advice: It is recommended that enterprises, before signing an agency agreement, check the commodity code through the "Export Tax Rebate Rate Inquiry" module of the e-Tax Bureau to avoid losses caused by adjustments to the tax rebate rate.