Recently, the Ministry of Finance and the State Administration of Taxation jointly issued Announcement No. 11 of 2026 to clarify and optimize the value-added tax and consumption tax policies for export business.
This adjustment is not “rebuilding from scratch”, but a continuation and refinement of the system to connect with the implementation of the new Value-Added Tax Law.
The overall policy remains stable, but the implementation details have sent a clear signal. If export companies do not adjust their operations in a timely manner, it may affect the efficiency of tax refunds and even the arrival of funds.
1. The scope of deemed exports is clearer, and tax refunds are also available for these businesses that “do not leave the country”
In the past, some businesses could still enjoy tax refunds if they met certain conditions but did not actually declare to leave the country.
This time the policy further clarifies the scope.
For example:
- Goods sold to special areas such as comprehensive bonded zones and bonded port areas are regarded as exports as long as the buyer is an enterprise or overseas unit in the zone;
- Providing aviation food for international flights and supplying goods for international transportation vehicles;
- Newly manufactured containers sold to overseas buyers are considered exports even if they are delivered to domestic yards;
- Even satellites and space vehicles “delivered in orbit” are also included in the scope of tax refunds.
Practical reminder: Enterprises should keep purchase and sale contracts, logistics documents and payment vouchers to ensure that transactions are authentic and purposeful to avoid tax refunds due to incomplete information.
2. There are new requirements for the tax rebate calculation method for imported processing, and the deduction of material and component costs is more standardized
Processing with imported materials is the main export mode for many manufacturing companies.
The New Deal puts forward more specific requirements for the calculation of taxable prices for “bonded imported materials”.
- Enterprises that adopt the “actual consumption method” determine the cost of consumed materials based on the export FOB price multiplied by the planned distribution rate;
- The planned distribution rate is determined by the import and export planned value in the customs manual, and the electronic account book refers to the actual write-off data of the previous period;
- For companies that adopt the “purchase method”, the actual CIF price of imported materials + tariffs + consumption tax are used as the tax calculation basis.
Practical reminder: Enterprises must link up with customs declaration and financial departments to ensure that the planned distribution rate is accurately reported to avoid tax refund amounts being reduced due to data deviations.
<img src="https://media.yunentropy.com/imgs/2026/01/08/fHsPar9zu.jpg" alt="Policy related images
- For customs declaration for export, the date of export on the customs declaration form shall prevail;
- For non-customs declaration for export (such as service export), the date of invoice issuance shall prevail;
- For export through the bonded area, the date of the actual departure document of the goods shall prevail.
Practical reminder: The invoicing time should match the export progress to avoid the misuse of tax rates caused by “early invoicing” or “delayed customs declaration”.
It is recommended that finance establish an export-invoicing-declaration timeline ledger.
4. When multiple tax refund rates coexist, they must be accounted for separately, otherwise “lower rather than higher”
If an enterprise exports products with different tax refund rates at the same time, such as some mechanical and electrical products with a 13% tax refund rate and the other 9% agricultural products, they must declare, calculate and declare separately.
If declarations are mixed together, the tax system will automatically apply the lowest tax refund rate, which may result in “wasted loss” of some tax refunds.
Practical reminder: It is recommended that enterprises set up “tax refund classification tags” in the ERP system and manage orders separately according to the tax refund rate to avoid mixed orders.
5. For water and electricity imported into special areas, the buyer shall apply for tax refund, and the seller will no longer refund the tax on his behalf
In the past, sellers who sold water, electricity, and gas to special areas could apply for tax refund from the seller.
It is now clear that for this type of business, the enterprise in the zone as the purchaser must declare tax refunds, and the seller is no longer eligible.
At the same time, it is emphasized that if enterprises in the zone use water and electricity for non-production purposes such as renting out factories, tax refunds will not be allowed, and the relevant input tax must be transferred to the cost.
Practical reminder: Seller companies should promptly inform customers (buyers in the area) of their tax refund responsibilities, keep sales vouchers and usage instructions, and prevent subsequent tax disputes.
