On January 30, 2026, the State Administration of Taxation issued the “Administrative Measures for the Refund (Exemption) of Value-Added Tax and Consumption Tax on Export Businesses” (State Administration of Taxation Announcement No. 5 of 2026, hereinafter referred to as “Announcement No. 5”), which will be officially implemented on January 1, 2026. This announcement fully replaces the Announcement No. 24 of 2012 that has been in use for many years.
As the “core supporting document” in the field of export tax rebates after the implementation of the “Value-Added Tax Law of the People’s Republic of China”, it follows the principles of “overall continuation, appropriate integration, policy connection, and pragmatic optimization”. While simplifying the process to “untie” enterprises, it also strengthens risk control and draws “red lines.”
The following is a detailed interpretation of the New Deal information, differences between the old and new, corporate impact, and practical strategies to help everyone quickly grasp the key points of the New Deal.
1. Core information of the New Deal: four major modules to handle the entire process of tax refund
Announcement No. 5 systematically standardizes the entire process of export tax refund (exemption), focusing on four major practical modules.
In terms of filing management, bid farewell to cumbersome forms. The original 5 forms are merged into one “Export Tax Refund (Exemption) Registration Form” to achieve “one form for everything”; changes in the filing content need to be applied within 30 days, and tax refund methods do not need to be settled first under certain circumstances; for enterprise mergers/divisions, tax refund matters can be undertaken by the new enterprise.
The declaration specification clarifies “who should report what and when”. Production enterprises must report value-added tax first and then apply for tax refund. Foreign trade enterprises must separately calculate the cost of export goods; processing of imported materials must write off the previous year’s manual (account) before April 30 of each year, and export goods must collect foreign exchange before April 30 of the following year after customs declaration.
In terms of certificates and document management, electronic versions of 9 types of tax refund certificates can be issued online, and paper versions can be issued on demand; within 15 days after applying for tax refund, “recording documents” such as purchase and sale contracts, transportation documents, etc. must be retained for 10 years, in both paper and electronic forms.
Risk control and penalties stipulate that tax refunds will not be temporarily granted under six categories of circumstances. Tax fraud will suspend tax refund rights based on the amount. False documents and refusal to verify will be punished in accordance with the law. In serious cases, criminal liability will be pursued.
2. Showdown between old and new!
Announcement No. 5 has 6 major changes
Compared with the old regulations in 2012, Announcement No. 5 has 6 major core changes, which can be said to be half benefit and half test.
The registration process has been “slimmed down”, the form is simple and changes are more flexible, and new enterprises can make supplementary tax refunds for compliant export business before registration.
The management of foreign exchange collection has been “relaxed” and the time limit for foreign exchange collection has been clarified. Overdue foreign exchange collection can be “deemed as foreign exchange collection” based on the materials. Only four types of enterprises need to submit additional foreign exchange collection materials when making declarations.
Electronicization has been “comprehensively accelerated”, and certificate issuance, declaration, and document filing can all be done online.
However, the retention of documents is “stricter”, with the retention period extended to 10 years and verification requirements must be met.
Risk control penalties are “precise” and the cost of violation has increased significantly.
There is a “fixed time limit” for the write-off of imported materials. The manual (account) book of the previous year must be written off before April 30 of each year. Tax refunds will not be given after the deadline.
3. Direct impact: How do different companies respond?
Announcement No. 5 presents the characteristics of “simplifying processes to reduce costs, tightening compliance and raising requirements”, and different companies will be affected to different extents.
The overall situation is good for manufacturing enterprises. The tax rebate method has been changed more flexibly, which alleviates financial pressure. However, attention should be paid to the time limit for verification of input materials and processing, and the pressure on document management has increased.
It is simpler for foreign trade companies to declare, but they must accurately distinguish business types and standardize input tax accounting, and the compliance requirements are higher.
Take a cross-border e-commerce company in Hangzhou that specializes in home furnishings as an example. It adopts the 9810 (export overseas warehouse) model. Under the old regulations, paper customs declaration forms and exchange receipt vouchers were required to be submitted offline, and there were many filing forms. After the implementation of the new policy, a single window can be used to declare online, and the exchange receipt vouchers are retained for future reference. The filing process is “one form”, which saves nearly 3 working days per month just sorting out the information, greatly improving efficiency.
4. Guide to avoid pitfalls: 4 practical suggestions to ensure tax refund compliance is correct
Enterprises can respond to the new policy changes and their own actual conditions.
The first is to sort out the filing and change process. Enterprises that are making tax refunds for the first time must prepare all the information. If the tax refund method is changed, they must first check whether they meet the conditions for “settlement exemption”.
The second is to standardize document management, retain filing documents as required, and establish an electronic index directory.
The third is to strengthen time limit management and set reminders for incoming material processing, write-off, and foreign exchange collection.
The fourth is to prevent compliance risks and regularly check the authenticity of business data and documents.
For cross-border e-commerce companies, they must adapt to electronic processes and optimize internal systems; optimize foreign exchange collection and overseas warehouse management, establish a foreign exchange collection ledger; standardize document retention, and sort out relevant documents based on the fragmentation of orders.
Announcement No. 5 serves as the “core management document” for export tax refunds after the implementation of the Value-Added Tax Law, with the goal of “smooth transition + simplified process + strengthened compliance.”
It brings benefits such as form simplification and electronic speed-up to enterprises, and also clarifies “red lines” such as 10-year document retention and refined risk control penalties.
Enterprises must seize the opportunity, take full advantage of the policy dividends, and at the same time maintain the bottom line of compliance to achieve long-term development of “compliance + efficiency”.
