Starting from 2026, there will be new changes in the export tax rebate policy.
At the end of January 2026, the State Administration of Taxation issued two core announcements, No. 5 of 2026 (“Measures for the Administration of Value-Added Tax and Consumption Tax Refund (Exemption) for Export Businesses”) and Ministry of Finance and State Administration of Taxation No. 11 of 2026, making major adjustments to the export tax refund declaration deadline, foreign exchange collection management, exchange rate conversion, and deemed domestic sales rules, which directly affect tax refund compliance and funding arrangements for foreign trade and production enterprises.
The following will give you a thorough, comprehensive and practical explanation from the aspects of policy basis and core points.
1. Policy basis (authoritative original text)
1. State Administration of Taxation Announcement No. 5 of 2026: “Administrative Measures for Value-Added Tax and Consumption Tax Refund (Exemption) for Export Business” (Declaration, Collection, Certification, Process)
2. Ministry of Finance
State Administration of Taxation Announcement No. 11 of 2026: “Announcement on Value-Added Tax and Consumption Tax Policies for Export Business” (Deemed as Domestic Sales, Period, Tax Calculation Calculation)
3.
Supporting: Article 17 of the “Regulations on the Implementation of the Value-Added Tax Law of the People’s Republic of China” (Exchange rate conversion rules)
2. Six core points (dismantled one by one)
(1) Declaration of tax refund: declare first and then verify and collect foreign exchange, dual-track regular period + supplementary period
1.
Regular declaration period: Starting from the month following the date of customs declaration for export→April 30 of the following year, tax refunds must be declared within each value-added tax declaration period (foreign trade enterprises can apply for tax refunds in non-declaration periods with approval); foreign exchange collection will not be verified for the time being (except for the fourth category of enterprises and enterprises that falsely collect foreign exchange). Tax refunds can be obtained after the declaration is approved.
2. Red line for foreign exchange collection (must be adhered to): If the tax refund has been declared and passed, the foreign exchange collection must be completed before April 30 of the year following the customs declaration for export; if the foreign exchange is not collected on time and does not qualify as deemed foreign exchange collection, the tax refunded (exempted) must be paid back, and the tax refund shall not continue to be enjoyed.
3. Supplementary declaration period (36-month grace period): If the tax refund (exemption) is not declared before April 30 of the following year, you can continue to apply for tax refund (exemption) within 36 months from the date of export by providing foreign exchange collection materials; if the tax refund (exemption) is not declared for more than 36 months, it will be directly regarded as domestic sales and taxed, and will no longer be treated as tax-free (rigid red line).
(2) Foreign exchange collection management: two time lines, overdue taxes must be paid
– Core deadline: foreign exchange collection before April 30 of the year following export (conventional red line)
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Deemed foreign exchange collection: In compliance with the “List of Reasons for Deemed Foreign Exchange Collection” in Annex 1 of the General Administration’s Announcement No. 5 (such as customer bankruptcy, force majeure, quality disputes, etc.), and retaining the “Foreign Exchange Collection Situation Form” + evidentiary materials, it can be treated as a deemed foreign exchange collection and no tax refund will be paid.
– Contract extension: If the contract stipulates that the exchange collection date is after April 30 of the following year, the exchange will be collected according to the contract, but it shall not exceed 36 months from the date of export at the latest.
(3) The boundary between the old and new declaration periods: old policy before 2025.12.31, new policy after 2026.1.1 (key transition)
– Export business before December 31, 2025 (inclusive): still implemented in accordance with the original policy – not applicable. Overdue 36 months will be regarded as domestic sales, and can be deferred and exempted according to the original rules, and are not subject to the rigid constraints of the new regulations.
– Export business after January 1, 2026 (inclusive): Strictly implement the 36-month final deadline – failure to declare after the deadline must be regarded as domestic sales, taxed at 13% (general goods), and no tax exemption.
(4) Exchange rate conversion: effective exchange rate + choice of two + unchanged for 12 months (new regulations are clear)
1. Optional criteria: the effective central parity rate of RMB exchange rate on the day of export or the 1st of the month (announced by the foreign exchange trading center authorized by the central bank)
2. Effective exchange rate definition: If the day/1st of the month is a holiday/weekend and there is no published exchange rate, the effective exchange rate on the last working day will be used.
3. Locking rules: The choice of one of the two methods cannot be changed within 12 months, and the tax calculation caliber should be kept consistent.
4. Revenue recognition: The revenue time point is determined based on the export date indicated on the export customs declaration, and the RMB sales are converted at the selected exchange rate.
(5) Deemed foreign exchange collection and supplementary reporting requirements
– Category four enterprises that declare after April 30 of the following year of export and are found to have falsely collected foreign exchange for less than 24 months must submit foreign exchange collection materials when reporting; other enterprises can keep it for future reference.
– Supplementary declaration (after April 30 of the following year of export): foreign exchange collection materials/deemed foreign exchange collection certificate must be submitted simultaneously, otherwise the tax refund will not be accepted.
(6) Income recognition: the export declaration date shall prevail
Article 41 of the “Implementation Regulations of the Value-Added Tax Law of the People’s Republic of China” (State Council Order No. 826) clearly stipulates that taxpayers export goods
, if the date of customs declaration for export is earlier than the time when the tax obligation occurs as specified in the first and second items of paragraph 1 of Article 28 of the Value-Added Tax Law of the People’s Republic of China, the time when the tax obligation occurs is the day when the goods are declared for export, and the income needs to be recognized based on the date when the tax obligation occurs (i.e., the date of export).
Among them, the first and second items of Article 28, Paragraph 1, of the “Value-Added Tax Law of the People’s Republic of China” clearly state that the time when the tax liability for taxable transactions occurs is the day when the sales payment is received, the claim voucher is obtained, or the invoice is issued, and the taxable transaction is deemed to be completed on the day.
3. Six core summaries
1. Tax refunds must be declared within each value-added tax return period starting from the month following the date of customs declaration of goods for export to April 30 of the following year, and the situation of foreign exchange collection will not be investigated for the time being (except for special enterprises).
However, if the tax refund application is approved, the foreign exchange shall be collected before April 30 of the following year following the date of export declaration.
2. If the tax has been refunded but the remittance has not been collected before April 30 of the following year, the refunded (exempted) tax shall be paid back.
3. If a taxpayer fails to apply for tax refund (exemption) within each value-added tax declaration period from the month following the date of export to April 30 of the following year, he may provide foreign exchange collection materials and continue to apply for tax refund within each value-added tax declaration period from April 30 of the following year to 36 months from the date of export declaration.
If the tax refund is not declared for more than 36 months, it will be directly regarded as domestic sales and will no longer be treated as tax exempt.
4. The original export business 26 years ago is not restricted!
Export business that is subject to VAT refund (exemption) or tax exemption policies that occurred before December 31, 2025 (inclusive) will still be implemented in accordance with the original policy provisions, and the provision that failure to declare within the 36-month period is deemed to be taxable on domestic sales does not apply.
5. For the export business exchange rate, select the effective exchange rate on the day of export or the 1st of the month.
The so-called effective exchange rate can be understood this way: if the day or the 1st of the month is a holiday or rest day, if there is no exchange rate announcement, the exchange rate of the previous working day will be selected.
6. Whether exported goods are subject to tax rebate, exemption or tax, even if the payment date stipulated in the export contract is later than the export date of the customs declaration, as long as the export date of the customs declaration is earlier, the export date will be regarded as the point in time when the tax liability is reached. Invoices will be issued in the current month or uninvoiced income, and the VAT sales will be reported in the declaration period of the next month.
