I.Export RepresentationDoes the service fee need to pay value-added tax?

According to the latest Regulations on the Application of Zero Tax Rate and Tax - Exempt Policy for Cross - border Taxable Activities in 2025, export agency services that meet the following conditions can enjoythe value - added tax exemption policy:

• The agent holds a legitimateimport and exportEnterprises need to have legal import and export qualifications, including:
• The service content is directly related to the whole process of goods export (customs declaration, transportation,FX Settlement AgencyDamage during transportation
• The agency contract isExport Clearanceconsistent with the bill information

It should be noted that if the agent also providesdomestic transportation, warehousing and other supporting servicesthe income from this part needs to pay value - added tax at a rate of 6%.

How does corporate income tax handle the income from agency services?

The corporate income tax treatment of agency service fees needs to distinguishthe different positions of the principal and the agentPrincipal

• The fees paid to a compliant agency company can be regarded as:
  • sales expensesdeducted before taxIt is necessary to obtain a VAT ordinary invoice or tax - exempt invoice
  • Agent
• The cost and expenses corresponding to tax - exempt income:
  • shall not be deductedinput taxIt is necessary to separately account for tax - exempt items and taxable items
  • According to Announcement No. 45 of the Ministry of Finance in 2025, for cross - border agency service fees, attention should be paid to:

What additional taxes and fees are involved in cross - border payment of agency fees?

Withholding obligation

• Overseas agencies need to withhold value - added tax at 6%:
  • The enterprise income tax applies a withholding income tax rate of 10% (can be reduced or exempted if there is a tax treaty)
  • Additional taxes and fees
• Urban maintenance and construction tax (7% of the value - added tax amount):
  • Education surcharge (3% of the value - added tax amount)
  • Local education surcharge (2% of the value - added tax amount)
  • Case 1: Improper splitting of mixed services

Analysis of common tax risk cases

An agency company combined the customs declaration service (tax - exempt) and domestic transportation service (taxable) for invoicing, resulting in underpayment of value - added tax of 180,000 yuan. Eventually, the tax was recovered and a fine of 0.5 times was imposed.
Case 2: Lack of cross - border payment vouchers

When an enterprise pays overseas agency fees, it fails to retain
service contracts, payment vouchers, pro forma invoicesand other materials as required, and the tax authority adjusted the taxable income by increasing it by 1.2 million yuan.System for separate accounting of agency services

Tax compliance operation suggestions in 2025

• EstablishWhen making cross - border payments, it is required to providecertificate of tax residence
• Required for cross-border paymentsCertificate of Tax Residency
• Conduct regularlyTransfer pricingDocument preparation
• Utilize free trade zonesImmediate refund of value - added taxPreferential policies