Publish Time: 2025-09-01 Origin: Site
I. Policy Background and Core Content
Recently, the State Administration of Taxation issued the "Announcement of the State Administration of Taxation on Optimizing Enterprise Income Tax Prepayment and Filing (No. 17 of 2025)" on July 7, 2025. This announcement sets new compliance requirements for the export business filing process and will officially take effect on October 1, 2025.
Core requirements include:
Export agent companies (including those operating through market procurement trade and comprehensive foreign trade services) must simultaneously submit basic information on the "actual exporter" and the corresponding export amount (i.e., the actual cargo owner's company name, unified social credit code/taxpayer identification number, and export amount) during the prepayment of enterprise income tax.
Failure to accurately submit this information will deem the business as "self-operated export," and the agent will be solely responsible for filing the entire enterprise income tax return for the corresponding export amount.
Ⅱ. Why is the "Bill-on-Export" model being ended?
"Bill-on-Export" refers to companies without import and export rights using the export credentials of others (such as freight forwarders or customs brokers) to conduct export operations. This practice carries serious risks, such as concealing the true trading entity, fabricating customs declaration documents, and even committing illegal tax refund fraud.
Document No. 17 explicitly breaks this model. Through institutional design, it compels export agents to disclose the true information of cargo owners, achieving transparency in trade practices and closing channels for false declarations. Furthermore, tax authorities will integrate the Golden Tax System (Phase IV) with customs, banks, and other information systems to conduct data penetration and verification, significantly improving regulatory accuracy.
III. Policy Implementation Impact and Risk Warnings
Penalty risks have increased across the board:
Failure to declare truthfully or providing false information may result in severe consequences, ranging from warnings, back taxes, fines, to criminal prosecution.
Tax authorities may discover anomalies when comparing prepaid and remitted tax data, triggering investigations, orders for back taxes, or even referrals to judicial authorities.
Compliance-based operations have become the industry mainstream:
Enterprises should proactively review export declarations, agency contracts, and tax reporting systems to ensure that information is accurate and consistent.
Freight forwarders and customs brokers should clearly define information provision obligations and accountability mechanisms in their contracts, sign the "Summary of Exports by Agents," and actively cooperate with the tax reporting process.
Ⅳ. Compliance Checklist (by role)
Manufacturers / Trading Companies (Actual Owners)
Provide accurate legal name and tax identification (Unified Social Credit Code) to your proxy/export agent.
Provide clear, auditable export transaction documentation (sales contracts, invoices, shipping docs).
Align internal accounting and tax records with customs declarations.
Review contracts to clarify tax and indemnity responsibilities.
Proxy Exporters / Freight Forwarders
Update service agreements to mandate truthful disclosure of the real owner and to include indemnity and liability provisions.
Maintain an entrusted-export ledger / summary that lists each transaction’s real owner details and export amount for tax filings.
Implement counterparty verification (KYC) and document validation processes.
Adopt dual-title customs declarations (proxy + real owner) where required.
Companies Without Export Rights (Previously Using “Buy-Order”)
Stop using arrangements that obscure the real owner.
Consider lawful alternatives: obtain export qualifications, establish a compliant trading arm, or use recognized market procurement programs (e.g., 1039 model where applicable).
Seek professional advice on retrospective tax exposure and how to remediate past non-compliant arrangements.
Ⅴ. Timeline & Implementation
August 1, 2025: Transition period recommended by the freight forwarder; businesses encouraged to begin following new procedures to align with Q3 reporting.
October 1, 2025: Full enforcement of the new requirements; non-compliant cases may be treated as self-export by proxies with corresponding CIT liabilities.
Ⅵ. Practical next steps (recommended)
Inventory current transactions that used buy-order arrangements and identify exposure.
Update standard contracts with clauses requiring real owner information and indemnities.
Coordinate with your freight forwarder / customs broker to implement dual-title declarations and maintain a transaction ledger.
Align accounting and tax filings with customs documentation to ensure consistency.
Obtain professional tax and legal advice for remediation of past non-compliant transactions or to convert business models.
Ⅶ. Conclusion
Announcement No. 17 marks the end of the shady "pay-for-export" operation. The policy's logic is to "penetrate real information." This policy strengthens the responsibility of agents for information authenticity while also enhancing the traceability of tax compliance throughout the entire trade chain. With the impending October 1st implementation deadline, companies must comprehensively adjust their business processes and strengthen compliance management to avoid significant tax and legal risks arising from false information.
Disclaimer
This article is prepared for general informational purposes only, based on a freight-forwarder notice and common industry practice. It does not constitute legal, tax, or customs advice. For authoritative guidance, consult official State Taxation Administration materials and your professional advisors.