I. Why the Tax Refund Process for 2026 Needs to Be Relearned
The institutional framework for export tax rebates underwent a rare comprehensive adjustment in 2026: a new announcement replaced several previously scattered old rules; the filing deadline changed from a single deadline of "April 30 of the following year" to a two-tier standard with a 36-month fallback window; and the retention timing and retention period for filing documents were also written into explicit provisions.
For enterprises, these changes are not just "good to know"—they directly determine whether an export transaction can ultimately be refunded, when action must be taken, and what materials must be kept. Steps that were previously handled based on experience now need to be rechecked against the new standards this year.
This article takes Announcement No. 11 and Announcement No. 2 of 2026 issued by the Ministry of Finance and the State Taxation Administration as its main thread, sorting out the core changes of the new policy, the operational actions enterprises need to adjust accordingly, and the situations most likely to cause tax rebate failure. It is suitable for finance staff, documentation clerks, and customs affairs managers of foreign trade enterprises to use for self-checking. For the policy content involved in this article, please refer to the original text of the latest announcements published on the official website of the State Taxation Administration.
II. Overview of 2026 Export Tax Rebate Policy Changes
The 2026 adjustments can be divided into two tracks: one is the reshaping of the institutional framework (Announcement No. 11), and the other is the adjustment of tax rebates for specific products (Announcement No. 2). The former changes "how it is administered," while the latter changes "whether it can be refunded."
2.1 Reshaping the Institutional Framework: Ministry of Finance and State Taxation Administration Announcement No. 11 of 2026
Announcement No. 11 was issued on January 30, 2026, and, in conjunction with the implementation of the Value-Added Tax Law of the People's Republic of China, sets out unified provisions on value-added tax and consumption tax policies for export business. The State Taxation Administration simultaneously issued the Administrative Measures for Value-Added Tax and Consumption Tax Refund (Exemption) on Export Business as supporting operational measures.
Main changes:
| Change | Details |
|---|---|
| Consolidation of rules | Consolidates multiple old export tax rebate regulations into a unified announcement basis, reducing cross-references among documents |
| Simplification of record-filing forms | The record-filing forms are consolidated from 5 into 1, and all 9 categories of certificates are fully digitized |
| Expansion of service exports | The scope of export business is expanded to cross-border sales of services and intangible assets; exports such as R&D, design, and software are subject to the corresponding measures |
| Restructuring of the filing deadline | Clarifies the regular deadline of April 30 of the following year + a 36-month window for late supplementary filing (see Section 3) |
| Codification of record-filing documents | The scope, retention time limits, and storage period of record-filing documents are written into the administrative measures (see Section 4) |
2.2 Adjustments for Specific Products: Ministry of Finance and State Taxation Administration Announcement No. 2 of 2026
Announcement No. 2 focuses on adjustments to the rebate rates for photovoltaic and other products, implemented in phases starting from April 1, 2026. This round involves a total of 271 tax codes:
| Product scope | Adjustment | Effective date |
|---|---|---|
| Photovoltaic industry chain (wafers, cells, modules, etc.), as well as some electronic and semiconductor materials, chemical and chemical raw materials, glass and glass products, building materials and stone, etc. | Cancel VAT export rebates, involving 249 tax codes | From April 1, 2026 |
| Battery products | Export rebate rate reduced from 9% to 6% | April 1 to December 31, 2026 |
| Battery products | Cancel VAT export rebates, involving 22 tax codes | From January 1, 2027 |
Two details are easily overlooked:
- The applicable rebate rate is determined by the export date specified on the customs declaration for the exported goods. For the same shipment, if the customs declaration date crosses an effective date, the applicable policy differs. In practice, "exporting before the adjustment" is based on the customs declaration date, not the contract signing date or production completion date—this point needs to be explained in advance when communicating delivery schedules with customers.
- For products subject to consumption tax, the export consumption tax policy will not be adjusted, and the consumption tax refund (exemption) policy continues to apply.
2.3 Three Actions Enterprises Need to Take to Adjust Accordingly
- Recheck the rebate rates for active products by HS code. Photovoltaic, battery, chemical raw materials, glass, and building materials-related categories are the first to be affected, and it is not advisable to rely on rebate rate memories from previous years; for other categories, it is also recommended to check item by item against the latest rebate rate database.
- Move rebate rate queries forward to the business negotiation stage. A reduction in the rebate rate will change the tax treatment result of an export transaction, so policy milestone dates should be taken into account when confirming price terms and delivery schedules with customers, rather than waiting until filing for the rebate to discover differences.
- Recalibrate the timing basis of the rebate filing ledger. Change from the single deadline of "April 30 of the following year" to a two-tier basis of "regular deadline + 36-month fallback," and distinguish the starting point under different export scenarios.
III. Detailed Explanation of the New 36-Month “Expired Means No Second Chance” Filing Rule
3.1 The Regular Filing Deadline Has Not Changed
Where goods exported by a taxpayer under customs declaration are eligible for the export refund (exemption) policy, the taxpayer shall, within each VAT filing period from the month following the date of customs declaration of export to April 30 of the following year, file for refund (exemption) and receive foreign exchange as required; if foreign exchange is not received before April 30 of the following year, the refunded (exempted) tax shall be paid back.
In other words, the “April 30 of the following year” deadline still exists, and foreign exchange receipt is still part of that deadline; it is not merely about the filing action.
3.2 The Newly Added 36-Month Supplementary Filing Window
If a filing cannot be made before April 30 of the following year, it may be made within each VAT filing period after April 30 of the following year and within 36 months from the date of customs declaration of export, provided that the relevant vouchers are collected in full and foreign exchange receipt materials are also provided at the same time, by filing for refund (exemption) with the competent tax authority.
Two keywords:
- Foreign exchange receipt materials — this is the additional threshold for overdue supplementary filing compared with regular filing. For filings within the regular deadline, foreign exchange receipt is handled according to regular requirements; when using the supplementary filing channel, foreign exchange receipt materials must be provided together.
- Calendar days — the 36 months are calculated by calendar days, not roughly estimated as “three years.” Business near the threshold must be calculated by actual days.
3.3 From Which Date Do the 36 Months Start?
The starting point depends on the export scenario and does not always start from the customs declaration date:
| Export scenario | Starting point of the 36 months |
|---|---|
| Goods exported under customs declaration | Date of customs declaration of export |
| Goods exported without customs declaration | Date of issuance of the export invoice or ordinary invoice |
| Goods exported from bonded zones and goods exported through bonded zones | Date of departure specified in the customs documents when the goods leave the territory |
| Water, electricity, and gas supplied to special areas | Date of issuance of the special VAT invoice obtained |
| Cross-border sales of services and intangible assets | Date when the tax obligation arises |
For most general trade export enterprises, the first row in the table applies — the date of customs declaration of export. However, if an enterprise also has bonded zone exports, cross-border service exports, and other businesses, its ledger cannot be established under only one basis.
3.4 What Happens After 36 Months?
If export goods are not filed for refund (exemption) within the 36-month period, they are deemed to be goods sold domestically, and VAT and consumption tax must be paid as required; if cross-border sales of services or intangible assets are not filed after the deadline, they are deemed to be services or intangible assets sold domestically; if water, electricity, or gas supplied to special areas is not filed for refund (exemption) after the deadline, the input tax amount is transferred to costs.
Pay special attention to the direction here: 36 months does not mean “it is still timely to handle it by the 36th month under an extension”; rather, it means “once this line is crossed, this business changes from tax refund to domestic-sales taxation.” Once overdue, the issue is tax payment, not tax refund.
3.5 Recommended Three Milestones for the Ledger
It is recommended to set reminders at three points in the tax refund filing ledger, rather than recording only one deadline:
| Milestone | Trigger action |
|---|---|
| Date of customs declaration of export | Establish a tax refund tracking record for the transaction, and register the customs declaration number, amount basis, and corresponding input invoice(s) |
| Before April 30 of the following year | Regular filing window; strive to complete filing and foreign exchange receipt by this milestone |
| Date of customs declaration of export + 36 months | Final milestone for the fallback window; entering this period requires preparing foreign exchange receipt materials at the same time |
For businesses with long document collection cycles and long foreign exchange receipt cycles, establishing the tracking record on the very day of customs declaration of export is far more reliable than sorting things out all at once at year-end.
IV. Record-Filing Documents: Retain Within 15 Days After Declaration, Keep for Ten Years
4.1 What Counts as Record-Filing Documents
The Measures for the Administration of Value-Added Tax and Consumption Tax Refund (Exemption) for Export Business classify record-filing documents into three categories:
| Category | Specific Documents |
|---|---|
| Purchase and sale contracts | Export contracts, comprehensive foreign trade service contracts, purchase contracts of foreign trade enterprises, purchase contracts under which manufacturing enterprises purchase non-self-produced goods for export, etc. |
| Transport documents for exported goods | Ocean bills of lading, air waybills, railway waybills, cargo carrier's receipts, postal receipts, and other cargo documents issued by carriers; domestic transport invoices for freight paid by the taxpayer; invoices for international freight forwarding service fees paid by the taxpayer, etc. |
| Customs declaration entrustment documents | Customs declaration entrustment agreements, agency customs declaration service fee invoices issued to the taxpayer by the entrusted customs declaration entity, etc. |
Exceptions may be made where, due to the characteristics of the transaction method, there are genuinely no corresponding record-filing documents; if the above record-filing documents cannot be obtained, other materials with similar content or function may be used as substitutes.
4.2 The Two Time Requirements Must Be Clearly Distinguished
| Time Requirement | Content |
|---|---|
| Within 15 days after declaration | Properly retain the record-filing documents, and prepare a Directory of Record-Filing Documents in the chronological order of refund (exemption) declarations, indicating the storage method of the record-filing documents |
| Ten-year retention period | Unless otherwise provided, the record-filing documents shall be stored and kept by the taxpayer and may not be damaged or destroyed without authorization |
“15 days” is the time limit for the retention action, not the expiration date of the materials. A common misunderstanding is conflating these two things—thinking that the materials are useless after 15 days, or that as long as the materials are retained, there is no need to prepare a directory. In fact, the directory and retention method are the first things checked during verification.
4.3 The Retention Method Can Be Chosen Freely
Taxpayers may choose to retain and keep them in paper, image, or digital form at their own discretion. Those choosing paper form must also indicate the storage location in the Directory of Record-Filing Documents; if the tax authority requires image or digital documents to be converted to paper for inspection, the taxpayer shall provide them as required, affix the official seal, and sign a statement that they are consistent with the original data.
For enterprises with a large volume of documents, image-based or digital retention can significantly reduce the pressure of paper archiving, but a searchable directory structure must be established at the same time—whether the documents for a particular shipment can be quickly located during verification depends on how clear the directory is.
4.4 Don't Confuse “Record Filing” with “Record-Filing Documents”
- Export Tax Refund (Exemption) Record Filing: the subject qualification record filing handled when first declaring export tax refund (exemption) or applying to issue an export tax refund (exemption) certificate; if the record-filing information changes, the change shall be handled within 30 days from the date the change occurs.
- Record-Filing Documents: the business materials retained in chronological order after each refund (exemption) declaration.
One is a qualification action at the enterprise level, and the other is a documentation action at the business level; they are not the same thing, and their processing time limits are completely different.
V. Export Tax Refund Operating Process (Declaration → Review → Treasury Refund)
5.1 Overall Process
Customs Export → Foreign Exchange Receipt → Obtain and Certify Input Invoices → Declaration Preparation → Online Declaration → Tax Authority Review → Treasury Refund Credited
5.2 Key Points at Each Stage
| Stage | Key Actions | Common Bottlenecks |
|---|---|---|
| Preliminary Preparation | Complete export tax refund (exemption) filing, confirm general taxpayer qualification, and register the bank account for tax refund treasury deposits | Filing not completed before the first declaration |
| Export and Document Collection | Collect customs declaration forms (electronic data of the copy specifically for export tax refund), input invoices, commercial invoices, packing lists, sales contracts, foreign exchange receipt vouchers, etc. | Incomplete documents or inconsistent information |
| Invoice Certification | After obtaining special VAT invoices, complete certification (select and confirm) on schedule | Failure to certify before the certification deadline |
| Online Declaration | Enter declaration data, perform data checks, and submit the formal declaration through the International Trade Single Window or the Electronic Tax Bureau | Customs declaration forms cannot be matched with invoices |
| Tax Authority Review | The system automatically reviews data matching and logical checks; manual verification for first-time tax refunds or questionable data; verification by letter when invoice authenticity is in doubt | Questionable data not explained in a timely manner |
| Treasury Refund Credited | After approval, the tax authority issues a tax refund certificate, and the People's Bank handles the treasury refund | Incorrect bank account information |
The actual duration of each step varies depending on the competent tax authority, the business circumstances, and the quality of the enterprise's own documents. The above nodes only reflect the sequence of the process; for specific time limits, please refer to the notice from the competent tax authority.
5.3 Pre-Declaration Self-Check List
- [ ] Customs declaration data has been pulled from the customs side and is consistent with the accompanying document information
- [ ] Input invoices have completed certification, and the product names, quantities, and specifications correspond to the customs declaration form
- [ ] The matching relationship between invoices and customs declaration forms has been checked invoice by invoice (the same invoice has not been repeatedly matched to multiple transactions)
- [ ] Foreign exchange receipt vouchers are complete, and the foreign exchange receipt progress meets the prescribed requirements
- [ ] The customs export date of this transaction has been registered, and both the April 30 of the following year and the 36-month milestones have been entered into the ledger
- [ ] The three categories of filing documents have been collected, a catalog has been prepared, and the storage method has been indicated
VI. Common Situations Where a Tax Refund Cannot Be Obtained and How to Avoid Them
6.1 Objective Conditions Not Met
| Situation | Reason | Preliminary Check |
|---|---|---|
| Export by small-scale taxpayers | Subject to the tax exemption without refund policy (except certain pilot regions) | Confirm the enterprise’s taxpayer status |
| Exported goods fall within the scope of canceled tax refunds | Such as the 249 tax code products covered by Announcement No. 2 of 2026 | Check the latest tax refund rate database by HS code |
| Goods with a tax refund rate of 0 | Certain high-energy-consumption, high-pollution, resource-based products | Same as above |
| Export without customs declaration or through informal channels | No customs electronic data; the tax system lacks a basis for declaration | Confirm that the goods actually completed customs declaration and left the country |
6.2 Problems in Operational Steps
| Situation | Reason | Avoidance Action |
|---|---|---|
| Failure to obtain special VAT invoices | Unable to prove that input VAT has been paid | Choose suppliers that can issue compliant special VAT invoices |
| Invoice exceeds the verification period | Verification was not completed within the prescribed period after the invoice was issued | Verify input invoices promptly upon receipt; do not let them pile up |
| Inconsistency between the goods name on the customs declaration and the invoice | The product names on the purchase contract, invoice, and customs declaration are not aligned | Keep the product name, quantity, and specifications consistent across the three documents |
| Failure to collect foreign exchange within the prescribed period | Inadequate accounts receivable management | Follow up on payment before maturity; if overdue, the refunded tax must be returned as required |
| No declaration filed for more than 36 months | No declaration ledger established; the business was forgotten | Set reminders according to the three milestones in Section 3 |
| Failure to cooperate with an on-site inspection triggered by a first tax refund | Filing materials not fully prepared | Cooperate with the inspection and organize filing materials in advance |
6.3 Compliance Risk Warnings
The following situations are no longer “operational errors” but illegal acts:
- Using falsely issued special VAT invoices to apply for a tax refund—the refunded tax will be recovered and a fine imposed; if the circumstances are serious, criminal liability will be pursued in accordance with the law;
- Matching the same invoice to multiple export transactions (invoice matching);
- Falsely reporting export prices to obtain a larger tax refund;
- Forging customs declarations, contracts, or other documents to fraudulently obtain tax refunds.
The bottom line for tax refund compliance is that the invoice, goods, payment, and documents are all consistent: what is purchased, what is exported, how much foreign exchange is collected, and how the documents are recorded should be mutually corroborating. This is more important than any operational technique.
VII. Implementation of Bofeng Logistics' Export Tax Rebate Services
The quality of export tax rebate declarations largely depends on whether the upstream documents are standardized. The completion of customs declaration forms, the consistency of product descriptions in documents, and the completeness of transport documents and customs declaration authorization materials all directly affect whether subsequent declaration matching can proceed smoothly.
Bofeng Logistics provides export customs declaration, document preparation, and customs consulting services for foreign trade enterprises, covering export stages from booking, trucking, and customs declaration to document archiving. If you encounter issues in tax rebate declarations such as inconsistent document specifications, incomplete filing documents, or anomalies in declaration data matching, you are welcome to contact us via the website inquiry form or the phone, WhatsApp, or Email at the bottom of the page. We will assist in sorting things out based on your specific business situation.
VIII. FAQ
1. Has the 2026 export tax rebate filing deadline actually changed?
The regular deadline has not changed; it remains from the month following the date of customs export declaration until April 30 of the following year. The change is the addition of an overdue supplementary filing channel: if a filing was not made before April 30 of the following year, it may be filed after April 30 of the following year and within 36 months from the date of customs export declaration, provided that all vouchers are collected and foreign exchange receipt materials are also provided.
2. Is the 36-month period counted from the customs declaration date, or from another date?
It depends on the export scenario. For goods exported under general trade with customs declaration, it starts from the date of customs export declaration; for exports without customs declaration, it starts from the date the invoice is issued; for bonded areas and exports through bonded areas, it starts from the date of exit specified in the customs documents; for water, electricity, and gas supplied into special areas, it starts from the date the special VAT invoice is issued; for cross-border sales of services and intangible assets, it starts from the date the tax liability arises. The 36 months are calculated in calendar days.
3. Can a tax rebate still be filed late after 36 months?
No. If exported goods are not declared for tax refund (exemption) within 36 months, they are deemed to be sold domestically, and VAT and consumption tax must be paid in accordance with regulations. In other words, after the deadline, the issue is tax payment, not tax refund.
4. When must record-filing documents be retained? For how long?
They should be properly retained within 15 days after filing for export tax refund (exemption), and a record-filing document index should be prepared in the order of filing time, indicating the storage method; unless otherwise specified, the retention period is ten years, and they must not be destroyed without authorization. Retention may be in paper, image, or digital form.
5. If a customer requests moving the export date earlier, can the applicable tax rebate policy be adjusted?
No. The applicable tax rebate rate is determined by the export date stated in the export goods customs declaration form. This date is determined by the actual customs declaration and cannot be adjusted through contracts or production arrangements. If the product's tax rebate rate is about to be lowered, delivery schedule arrangements need to be communicated with the customer in advance.
6. What is the current tax rebate rate for battery products?
From April 1 to December 31, 2026, the export tax rebate rate for battery products will be reduced from 9% to 6%; from January 1, 2027, the VAT export tax rebate for battery products will be cancelled, involving 22 tax code items. The specific rate shall be subject to the latest export tax rebate rate database corresponding to the product's HS code.
7. Can small-scale taxpayers get tax rebates on exports?
Generally, the tax exemption without refund policy applies (except in some pilot areas). If small-scale taxpayers need tax rebates, it is recommended to first confirm taxpayer status with the competent tax authority before deciding on business arrangements.
9. Further Reading
- Complete Export Tax Rebate Process: Application Conditions, Rebate Rate Query, and Latest Policies (Complete version covering rebate conditions, rebate rate query methods, application process, and calculation methods)
- Guide to Export Tax Rebate Application Deadlines and Overdue Handling (Basis for application deadlines and handling paths for overdue situations)
- What Is the Export Tax Rebate? How Do Export Enterprises Apply for a Tax Rebate? | What is re-export tax refund? | Notes for Export Proceeds Verification Forms
- Customs Release and Customs Closure: Electronic Release vs. Manual Release, and the Relationship Between Customs Closure Time and Tax Rebate (Linkage between customs closure data and tax rebate applications)
- Sister articles in the September documentation series: Customs Declaration Form Completion Standards and Common Errors (Declaration Elements + HS Classification) | Practical Guide to RCEP Tariff Concessions and FTA Certificates of Origin (Form E / Form RCEP Application) | Guide to Southeast Asia Ocean Freight Documentation and the Application of RCEP Certificates of Origin
- Guide to Preparing Core Customs Documentation: Detailed Explanation of Invoice, Packing List, and Contract Templates | Full Comparison of Certificate of Origin Applications: CO / FORM A / FORM B / FORM E / FORM F / FTA / RCEP
- The Complete Guide to Customs Declaration and Clearance (Complete chapters on customs declaration basics, documentation, HS codes and tariffs, and handling customs clearance exceptions)
This article was compiled by the Bofeng Logistics team and verified in September 2026. The policy content herein is based on the Ministry of Finance and State Taxation Administration Announcements No. 11 and No. 2 of 2026 and the State Taxation Administration's Measures for the Administration of VAT and Consumption Tax Refund (Exemption) for Export Business; rebate rates and application deadlines may change with policy adjustments. For actual applications, please refer to the latest official announcement texts published on the State Taxation Administration's official website, the Export Tax Rebate Rate Database, and the competent tax authorities' interpretations. If you need export customs declaration, documentation preparation, or customs affairs support, please contact us through the website inquiry form (phone / WhatsApp / Email are at the bottom of the page).
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