Have all sellers felt the wind of compliant export? In July, the State Taxation Administration issued the Announcement on Matters Concerning Optimizing the Declaration of Enterprise Income Tax Prepayment (No. 17 of 2025), drawing a clear "compliance red line" for agent export businesses.

Policy Core: Two Key "Hard Rules" of Announcement No. 17 for Sellers

01 The "word maze" of the policy is indeed a headache.

In fact, there are only two core requirements for agent export in Announcement No. 17:

First, the information on agent export must be reported, and "failure to report" means paying income tax on behalf of others. In the past, during agent export, many sellers relied on freight forwarders or agent companies to "package and handle" the declaration, and they were not aware of the specific declaration details.

However, the new regulation clearly states that all enterprises that export through means such as agency, market procurement trade, and foreign trade comprehensive services must simultaneously report the "information of the actual principal exporter" and the "export amount" during the prepayment declaration, and must fill in the "Summary Table of Entrusted Exports by Agent Export Enterprises".

Here, the "actual principal exporter" refers to us cross-border sellers—the entity that actually produces or sells the exported goods.

If the agent company fails to report this information accurately, the business will be deemed as "self-operated export" by the agent company, and the agent will be liable for paying the corresponding enterprise income tax. However, agent companies will not bear this cost out of thin air; ultimately, they will either pass it on by raising prices, demand that sellers make up the tax payment, or even refuse cooperation outright.

Second, "truthful declaration" of export income is required, with a clear distinction between self-operated and entrusted exports. The new regulation clarifies the "ownership issue" regarding the declaration of export income: Sellers engaged in self-operated export must declare the income from the production and sale of their own goods; sellers who entrust agents for export must have the agent company declare the "income from the export of goods entrusted by the enterprise". This rule essentially closes the loophole of "buyer-arranged export" (a non-compliant practice where sellers use third-party agents' qualifications to export without proper entrustment procedures) that existed in the past.

Previously, some sellers, for the sake of convenience, exported goods in the name of other companies without declaring their own income. This practice will become completely unfeasible after October 1st. The tax system will conduct comparisons based on the "flow of goods, capital, and invoices". Once a discrepancy is found between the declared income ownership and the actual situation, an audit will be triggered.

02 Seller Preparation: How to Avoid Business Disruption Before Policy Implementation?

To ensure that shipments are not affected after the new regulation takes effect, it is recommended to proceed from two aspects: "compliance verification" and "document preparation":

1. First, verify whether the agent export business is compliant

Zhongjing has already started contacting customers one by one. If you have not received a notification yet, please take the initiative to contact your counterpart and focus on confirming the following two issues:

• Whether the current agent export model complies with the new regulation (e.g., whether it can provide complete information of the "actual principal", including company name, unified social credit code, details of exported goods, etc.);
• Whether the existing cooperative agent company has the "compliant declaration capability" and can fill in the Summary Table of Entrusted Exports by Agent Export Enterprises on time.

2. Second, ensure that the "forms for agent export business are properly stamped"

For all entrusted export businesses, the Summary Table of Entrusted Exports by Agent Export Enterprises must be filled out in accordance with requirements and affixed with the official seal. Note: The "export amount", "goods name", and "principal information" in the form must be consistent with the customs declaration form and contract. Any filling errors or omissions will result in declaration failure.

Seller A: "I run a small and micro enterprise and don’t have an official seal. What should I do?"

According to tax requirements, individual industrial and commercial households can provide the person-in-charge’s signature plus a copy of the business license, but must ensure that the information is true and traceable.

Special Reminder 1: Zhongjing will not accept any business for which complete and valid stamped/signed forms are not provided.

If you still need agent export services due to your own qualifications (e.g., no import-export rights), Zhongjing will recommend "well-known import-export agent companies" at your local port (you can obtain the list from your counterpart manager).

Special Reminder 2: Zhongjing only provides recommendations and will not participate in subsequent business operations or assume relevant responsibilities.

03 Long-Term Paths: 2 Recommended Compliance Paths for Sellers to Choose as Needed

There is no need to panic in the face of Announcement No. 17. By choosing the right path based on your own situation, you can achieve stable overseas expansion:

Path 1: For eligible sellers, prioritize "self-operated export" (more independent)

If your company has already obtained import-export rights and has a professional financial team, it is recommended to switch directly to the self-operated export model.

• Income and tax refunds are directly attributed to your own company, avoiding the risk of "information asymmetry" in the agency link;
• You can independently enjoy the enterprise income tax credit policy for energy-saving, water-saving, and environmental protection equipment (Article 1 of the new regulation clearly states that such policies can be enjoyed during prepayment, without waiting for the annual final settlement);
• Subsequent coordination with logistics and customs declaration is more flexible, without relying on the declaration progress of the agent company, resulting in higher efficiency.

Path 2: Temporarily need agent export? Conduct "3 verifications" before cooperation (more secure)

If self-operated export is not feasible for the time being, be sure to conduct the following 3 verifications when choosing agent export:

• Verify the other party’s compliance qualifications: completeness of qualifications, scale and reputation, and whether it is a pure agent;
• Verify the safety boundaries of capital and tax refunds: foreign exchange collection process and capital security, tax refund process and cycle, etc.;
• Verify the cost composition: whether the agency fee includes "compliant declaration costs" to avoid additional charges later.

From the ambiguous operation of "buyer-arranged export" to the clear requirement of "mandatory information reporting and truthful income declaration" in Announcement No. 17, the core of the policy is not to "restrict exports", but to standardize the market and create a more fair competitive environment for sellers with compliant operations. What seems to be a constraint is actually helping compliant sellers eliminate non-compliant competitors.

October 1st is not a "deadline", but a "starting line" for compliance. Zhongjing will take every solid step with you!