Policy Overview
In 2025, China issued State Taxation Administration Announcement No. 8 of 2025, which strictly prohibits “bill purchasing exports” — a practice where companies without import/export qualifications use another party’s name to export goods and evade taxes. Key requirements include:
- Exported taxable goods must be treated as domestic sales and pay VAT and consumption tax.
- Tax registration confirmation must be completed before export.
- Companies must complete tax clearance before business deregistration.
The policy aims to close tax loopholes, maintain fair market competition, and promote high-quality foreign trade.
Key Impacts on Overseas Buyers
- Compliance Risk
Using unqualified suppliers may trigger scrutiny from Chinese tax authorities or customs. - Supply Chain Delays and Increased Costs
Mandatory tax registration and verification can extend export timelines. - Financial and Tax Refund Risks
Non-compliant exports may lead to VAT refund issues or additional tax liabilities. - Contractual and Legal Risks
Contracts without clear responsibilities may result in disputes.
CPA-Recommended Compliance Strategies
- Verify Supplier Qualifications: Ensure suppliers hold valid import/export licenses.
- Maintain Proper Documentation: Keep full sets of customs declarations, contracts, and invoices for traceability.
- Use Compliant Payment Channels: Process payments through official corporate accounts or regulated platforms.
- Sign Formal Agency Agreements: Clearly define responsibilities and risk allocation.
- Stay Updated on Policy Changes: Monitor the State Taxation Administration and General Administration of Customs websites.
Conclusion
China’s 2025 regulations show a strong commitment to export tax supervision. Overseas buyers should prioritize compliance, select reliable suppliers, and maintain proper documentation to ensure smooth, safe exports while minimizing financial and legal risks.
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