Attention all export business owners and financial partners!
In 2026, the State Administration of Taxation issued two major documents, namely Document No. 5 of 2026 (“Measures for the Administration of Value-Added Tax and Consumption Tax Refund (Exemption) for Export Business”) and Document No. 11 (Announcement on Value-Added Tax and Consumption Tax Policy for Export Business). These two documents will officially take effect from January 1, 2026, and all relevant old policies (such as Document No. 24 of 2012) will be invalidated.
Let’s take a look at the five core changes in the new policy compared with the old policy:
Change 1: The time for filing tax refunds is looser
In the past, after exporting goods, tax refund declarations had to be completed before the VAT declaration period in April of the next year. If the deadline is exceeded, it will be regarded as domestic sales and tax payment.
Many companies pay more taxes because they do not have all the customs declaration forms and foreign exchange receipts.
The new policy will extend the tax refund (exemption) and tax exemption declaration period to “36 months from the date of tax liability.”
In other words, there used to be only a few months to declare, but now there are three years.
However, it should be noted that goods exported before December 31, 2025 will be subject to the old rules, and the new 36-month period will be adopted from January 1, 2026.
Change 2: Simplified tax refund process
In the past, tax refund policies were scattered, and the rules for tax refunds for goods and cross-border services were different. When filing and submitting documents, the process was cumbersome.
The new policy integrates full-process management requirements, unifies the tax refund (exemption) rules for goods and cross-border services, simplifies the filing process, handles filing when filing for the first time or issuing a certificate, and streamlines the submission of materials; standardizes the handling of declaration errors, unapproved declarations can be withdrawn directly, and approved declarations need to be offset with negative amounts.
Change 3: The scope of tax rebate is tightened
In the past, winning bids for mechanical and electrical products and marine engineering structures, old and new, were basically regarded as export tax rebates.
The new policy tightens the scope of deemed exports, deletes old mechanical and electrical products, eliminates models of marine engineering structures, and clarifies that winning bids for mechanical and electrical products are limited to brand-new products.
Change 4: Integration of consumption tax refunds
In the past, VAT refunds and consumption tax refunds were declared separately, and two sets of information were required, which was easy to make mistakes or omissions.
The new policy implements “integrated declaration” of VAT and consumption tax refunds (exemptions). Consumption tax refunds (exemptions) must be submitted simultaneously with the corresponding VAT declarations, simplifying the consumption tax declaration form and clarifying the data submission requirements.
Change 5: Accounting confirmation of sales revenue is required before tax refunds can be made
Although the business was required to be genuine in the past, it was not clarified that “accounting confirmation of sales revenue” was a mandatory condition for tax refund.
The new policy stipulates that export goods subject to the value-added tax refund (exemption) policy must also meet conditions such as sales to overseas entities or individuals, declaration to customs and actual departure from the country, sales in accordance with accounting systems, and collection of foreign exchange in accordance with regulations.
In practice, there are 5 pitfalls that you must not step into:
1. The 36-month period is not unlimited. Failure to declare after the deadline will still be regarded as domestic sales and tax payment. It is recommended to establish a ledger based on the export date and check it regularly.
2. The filing must be compliant and operate in accordance with the requirements of Document No. 5. When reporting, prepare information in accordance with the new regulations. For RMB settlement business, just provide RMB receipt voucher.
3. Compare the new catalog in Document No. 11 to confirm that export products are within the tax refund scope to avoid illegal tax refunds.
4. When exporting taxable consumer goods, value-added tax and consumption tax must be declared simultaneously, and all information must be prepared to prevent omissions and misreporting.
5. Be sure to confirm sales revenue in accounting before declaring tax refund. When confirming revenue from foreign currency settlement export business, the exchange rate selection must comply with regulations. It cannot be changed within 12 months after selection, and the tax refund exchange rate must be consistent with the VAT declaration exchange rate.
Generally speaking, these two new policies in 2026 will “reduce and relax the burden” on export enterprises, but also tighten the scope of tax rebates and add the requirement of “accounting confirmation of sales revenue”.
All bosses and financial personnel should carefully read the original text of Document No. 5 and No. 11, adjust the company’s tax refund process and accounting, and while enjoying the policy dividends, avoid compliance pitfalls and make the export business more stable.
