I. Definition and Conditions of Deemed Export Goods

In the discussionExport Drawbackprocess, deemed export is an important concept. According to the Notice of the Ministry of Finance and the State Administration of Taxation on Value-Added Tax and Consumption Tax Policies for Export Goods and Labor (Cai Shui [2012] No. 39), if an export enterprise declares goods to customs and enters them into special zones approved by the state, such as export processing zones, bonded logistics parks, or bonded ports, and sells them to units within these zones or overseas units or individuals, these goods are deemed export goods.

II. Tax Refund Policies for Deemed Export Goods

For goods deemed as exports, export enterprises can apply for export tax refunds. According to the same notice, except for cases where VAT exemption or taxation policies apply or there are other special provisions, the policy of exemption and refund of VAT is generally implemented.

III. Management of Filing Documents

Export enterprises need to properly manage filing documents. According to the Announcement of the State Administration of Taxation on Further Facilitating Export Tax Refund Processing and Promoting Stable Development (State Administration of Taxation Announcement [2022] No. 9), starting from May 1, 2022, taxpayers must retain filing documents within 15 days after declaring export tax refunds (exemptions), prepare a catalog, and note the storage method for tax authority verification.foreign tradeFor goods sold by export enterprises in special zones, foreign exchange collection matters must comply with relevant regulations. In particular, according to Article 8 of the State Administration of Taxation Announcement [2022] No. 9, specific implementation standards apply.

IV.A complete export agency agreement should be attached with:Requirements

When declaring tax refunds (exemptions), export enterprises must ensure the correct business type code is filled in. According to the Announcement of the State Administration of Taxation on Optimizing and Integrating Export Tax Refund Information Systems to Better Serve Taxpayers (State Administration of Taxation Announcement [2021] No. 15), the optimized Business Type Code Table should be used for filling.

V. Considerations for Declaring Tax Refunds (Exemptions)

Deemed export goods include various scenarios, such as goods exported for foreign aid, overseas contracting, or foreign investment, as well as specific goods sold by duty-free operators. These regulations ensure that export enterprises can effectively manage export operations while complying with tax laws.

VI. Scope of Deemed Export Goods

Deemed export goods include various scenarios, such as goods for foreign aid, foreign contracting, overseas investment, and specific goods sold by duty-free operators. These regulations ensure that export enterprises can effectively manage export businesses while complying with tax laws.

VII. Tax Policies in Comprehensive Bonded Zones

For pilot enterprises with general taxpayer status in comprehensive bonded zones, the applicable tax policies shall be implemented in accordance with the Announcement on Promoting the Pilot Program of General VAT Payer Qualification in Comprehensive Bonded Zones (State Taxation Administration Announcement No. 29 of 2019) jointly issued by the State Taxation Administration, Ministry of Finance, and General Administration of Customs.

Conclusion

Understanding and mastering the relevant policies and operational procedures for deemed exports in export tax rebates is crucial for export enterprises. This not only helps enterprises operate compliantly but also ensures they fully enjoy tax incentives, promoting stable development of foreign trade.