Announcement of the Ministry of Finance and the State Taxation Administration on Value-Added Tax and Consumption Tax Policies for Export Business
Announcement of the Ministry of Finance and the State Taxation Administration on Value-Added Tax and Consumption Tax Policies for Export Business
Announcement of the Ministry of Finance and the State Taxation Administration on Value-Added Tax and Consumption Tax Policies for Export Business
Announcement of the Ministry of Finance and the State Taxation Administration [2026] No. 11
January 30, 2026
To ensure the policy alignment following the implementation of the Value-Added Tax Law of the People's Republic of China and the Implementation Regulations of the Value-Added Tax Law of the People's Republic of China, and to continue the current system and practices, the following announcement is made regarding the application of value-added tax (VAT) and consumption tax refund (exemption), exemption, or taxation policies for exported goods and cross-border sales of services and intangible assets (hereinafter collectively referred to as "export business"):
I. Export Business Subject to the VAT Refund (Exemption) Policy
The following export business conducted by taxpayers, except for the circumstances specified in Articles VI and VII of this Announcement, shall be subject to the VAT refund (exemption) policy:
(I) Exported goods.
1. Exported goods subject to the VAT refund (exemption) policy shall, except for the circumstances listed in Sub-item 2 of this Item, meet all of the following conditions:
(1) Sold to overseas entities or individuals;
(2) Declared to Customs and actually leaving the territory of China;
(3) Accounted for as sales in accordance with the accounting system; and
(4) Foreign exchange collection completed in accordance with regulations.
2. The following circumstances constitute deemed exported goods and shall be subject to the VAT refund (exemption) policy:
(1) Goods declared to Customs and entered into State-approved bonded port areas, comprehensive bonded zones, the Zhuhai Park of the Zhuhai–Macao Cross-Border Industrial Zone, or bonded logistics centers (Type B) (hereinafter collectively referred to as “special zones”), and sold to entities or individuals in special zones or to overseas entities or individuals.
(2) Goods sold by enterprises with duty-free goods business qualifications, foreign-invested enterprises approved by the State Council to participate in duty-free shop operations, and enterprises with offshore duty-free goods distribution qualifications (hereinafter collectively referred to as "relevant duty-free goods enterprises"), excluding goods prohibited from being traded or restricted for export by the State (see Attachment 1), cigarettes, and goods beyond the prescribed business scope of duty-free shops. Specifically, these refer to goods uniformly procured by relevant duty-free goods enterprises and sold in their affiliated port departure duty-free shops, downtown duty-free shops, and offshore duty-free shops in compliance with regulations.
(3) Bid-winning electromechanical products sold for use in international bidding construction projects financed by international financial organizations or foreign government loans (hereinafter referred to as "bid-winning electromechanical products"). The specific scope of lending institutions and bid-winning electromechanical products is provided in Attachment 2.
(4) Self-produced offshore engineering structures that are sold to Sino-foreign cooperative oil (gas) field exploitation enterprises and are subject to VAT on a physical basis. The specific scope of offshore engineering structures and Sino-foreign cooperative oil (gas) field exploitation enterprises is provided in Attachment 3.
(5) Goods sold to international transport enterprises for use on international conveyances. Specifically, these refer to goods sold by taxpayers to international transport enterprises for use on international transport vessels, and aviation food produced and sold by domestic aviation supply companies to domestic and foreign airlines for international flights.
(6) Water (including steam), electricity, and gas sold to taxpayers within special zones for consumption in the production of goods, provision of processing services, and repair and replacement services, and supplied to special zones without being declared to Customs (hereinafter collectively referred to as "water, electricity, and gas supplied to special zones").
Water, electricity, and gas supplied to special zones shall be declared for VAT refund (exemption) by the purchasing taxpayers in the special zones. Taxpayers in the zones who use such supplies for leasing or transferring factory buildings shall not declare VAT refund (exemption), and the input tax amount shall be transferred to costs.
(7) Newly manufactured containers declared to Customs, delivered to designated depots within the territory of China, and sold to overseas entities or individuals.
(8) Spacecraft and related goods delivered in orbit.
In-orbit delivery refers to the business activities in which spacecraft and related goods are launched into a predetermined orbit and then delivered for use by domestic or overseas entities or individuals.
Spacecraft and related goods include satellites, space probes, and other spacecraft and their components, parts, satellite payloads, satellite TT&C system equipment, software, facilities, etc.
(9) Goods used for overseas contracted projects, outbound investment, and foreign aid projects funded by preferential loans.
Unless otherwise provided in this Announcement or in other provisions issued by the Ministry of Finance and the State Taxation Administration, deemed exported goods shall be subject to the provisions applicable to exported goods.
3. Exported goods referred to in this Announcement include self-operated exported goods and entrusted exported goods.
(II) Cross-border sales of services and intangible assets.
1. The following services and intangible assets sold to overseas entities and fully consumed outside the territory of China:
(1) R&D service.
(2) Contract energy management service.
(3) Design service.
(4) Radio, film, and television production and distribution service.
(5) Software service.
(6) Circuit design and testing service.
(7) Information system service.
(8) Business process management service.
(9) Offshore service outsourcing business.
Offshore service outsourcing business includes information technology outsourcing service (ITO), technical business process outsourcing service (BPO), and technical knowledge process outsourcing service (KPO).
(10) Technology transfer.
The specific business activities involved in this Sub-item shall be implemented in accordance with the corresponding business activities in the Explanatory Notes on the Sale of Services, Intangible Assets and Immovable Property published by the Ministry of Finance and the State Taxation Administration. The specific scope of offshore service outsourcing business is provided in Attachment 4.
The term "fully consumed outside the territory of China" as mentioned in this Announcement refers to:
(1) The actual recipient of the service is located outside the territory of China, and the service is unrelated to goods, immovable property, or natural resources within the territory of China.
(2) The intangible assets are used entirely outside the territory of China, and are unrelated to goods, immovable property, or natural resources within the territory of China.
(3) Other circumstances stipulated by the Ministry of Finance and the State Taxation Administration.
2. International transportation services. Specifically, this refers to:
(1) Transporting passengers or goods from within the territory to outside the territory of China.
(2) Transporting passengers or goods from outside the territory into the territory of China.
(3) Transporting passengers or goods outside the territory of China.
3. Space transportation services refer to the business activities of launching spacecraft, such as satellites and space probes, into space orbit using carriers like rockets.
4. Outward repair and replacement services refer to the repair and replacement services provided for goods imported for re-export or for conveyances engaged in international transport.
II. VAT Refund (Exemption) Methods
For export business subject to VAT refund (exemption) policy apply, taxpayers shall adopt the tax exemption-credit-refund method or the tax exemption-refund method in accordance with the following provisions.
(I) Tax exemption-credit-refund method.
For export business, taxpayers are exempted from VAT at the export stage, and the corresponding input tax amount is offset against the VAT payable (excluding VAT taxable calculated according to the VAT collection-and-refund-upon-levy or VAT refund (or rebate) after levy, or simplified tax calculation methods). The uncredited portion shall be refunded. The applicable scope includes:
1. Export of self-produced goods and goods deemed as self-produced goods by manufacturing enterprises (the specific scope of goods deemed as self-produced goods is provided in Attachment 5).
2. Export of non-self-produced goods by designated manufacturing enterprises (the specific scope of such enterprises is provided in Attachment 6).
3. Cross-border sales of services and intangible assets by manufacturing enterprises.
4. Direct export of services or self-developed intangible assets by foreign trade enterprises, which shall be treated as manufacturing enterprises and subject to the tax exemption-credit-refund method together with their exported goods.
The term "manufacturing enterprises" as mentioned in this Announcement refers to taxpayers with production capacity; "foreign trade enterprises" refer to taxpayers without production capacity.
(II) Tax exemption-refund method.
Where foreign trade enterprises or other entities export goods or conduct cross-border sales of externally purchased services or intangible assets, VAT at the export stage shall be exempted, and the corresponding input VAT shall be refunded.
III. VAT Export Refund Rates
(I) Except for the VAT export refund rates explicitly determined by the Ministry of Finance and the State Taxation Administration based on the decisions of the State Council (hereinafter referred to as "refund rates"), the refund rate applicable to export business shall be the applicable tax rate. The State Taxation Administration shall publish the refund rates through the tax refund rate database in accordance with the above provisions.
Unless otherwise provided, the effective time of the refund rates for export business shall be determined as follows:
1. For exports declared to Customs (excluding exports from bonded zones and exports via bonded zones), the export date specified on the customs declaration form for exported goods shall prevail.
2. For exports not declared to Customs, the issuance date of the export invoice or ordinary invoice shall prevail.
3. For exports from bonded zones and exports via bonded zones, the exit date specified on the documents issued by Customs at the time of goods departure from the territory shall prevail.
(II) Other provisions on refund rates.
1. For export goods, services, and intangible assets purchased by foreign trade enterprises taxed under the simplified tax calculation method, or those purchased from small-scale taxpayers, the refund rates shall be the levy rate actually applied under the simplified tax calculation method or the levy rate applicable to small-scale taxpayers, respectively. Where special VAT invoices are obtained for the above export business, the refund rate shall be determined in accordance with the principle of applying the lower of the VAT rate (levy rate) indicated on the special VAT invoice and the refund rate applicable to the export business.
2. For outward repair and replacement services provided by taxpayers, the refund rate shall be the refund rate for the repaired and maintained goods; for goods exported after being retrieved from entrusted processing, and for goods exported after being retrieved from entrusted repair and replacement, the refund rate applicable to the processing or repair and replacement fees shall be the refund rate applicable to the exported goods.
3. For bid-winning electromechanical products; listed raw materials sold to taxpayers in special zones for production consumption after customs declaration and entry into special zones (hereinafter referred to as "listed raw materials," the specific scope of listed raw materials is provided in Attachment 7); water, electricity, and gas supplied to special zones; space transportation vehicles and related goods purchased for space transportation services, as well as launch and operation support services; and spacecraft and related goods delivered in orbit, the refund rate shall be the applicable tax rate.
When the State adjusts the refund rate for listed raw materials, the listed raw materials shall be subject to the adjusted refund rate from the date of adjustment.
Space transportation vehicles and related goods include rockets, space shuttles, and other space vehicles and their components, parts, and propellants.
Launch and operation support services include measurement and control, research and development, design, testing, inspection, supervision, space system integration services related to launch activities and in-orbit delivery; technology transfer, technical coordination, technical consulting, full life cycle services for spacecraft; orbit (frequency) application, consulting, and leasing services; cooperation, purchase, and leasing services for satellite payloads; space product transportation, space-related training services; exhibition and display of space product facilities and technology, and other related services.
(III) Where export business is subject to different refund rates, such export business shall be separately declared to Customs, separately accounted for, and separately declared for tax refund (exemption).
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Announcement of the Ministry of Finance and the State Taxation Administration [2026] No. 11
January 30, 2026
To ensure the policy alignment following the implementation of the Value-Added Tax Law of the People's Republic of China and the Implementation Regulations of the Value-Added Tax Law of the People's Republic of China, and to continue the current system and practices, the following announcement is made regarding the application of value-added tax (VAT) and consumption tax refund (exemption), exemption, or taxation policies for exported goods and cross-border sales of services and intangible assets (hereinafter collectively referred to as "export business"):
I. Export Business Subject to the VAT Refund (Exemption) Policy
The following export business conducted by taxpayers, except for the circumstances specified in Articles VI and VII of this Announcement, shall be subject to the VAT refund (exemption) policy:
(I) Exported goods.
1. Exported goods subject to the VAT refund (exemption) policy shall, except for the circumstances listed in Sub-item 2 of this Item, meet all of the following conditions:
(1) Sold to overseas entities or individuals;
(2) Declared to Customs and actually leaving the territory of China;
(3) Accounted for as sales in accordance with the accounting system; and
(4) Foreign exchange collection completed in accordance with regulations.
2. The following circumstances constitute deemed exported goods and shall be subject to the VAT refund (exemption) policy:
(1) Goods declared to Customs and entered into State-approved bonded port areas, comprehensive bonded zones, the Zhuhai Park of the Zhuhai–Macao Cross-Border Industrial Zone, or bonded logistics centers (Type B) (hereinafter collectively referred to as “special zones”), and sold to entities or individuals in special zones or to overseas entities or individuals.
(2) Goods sold by enterprises with duty-free goods business qualifications, foreign-invested enterprises approved by the State Council to participate in duty-free shop operations, and enterprises with offshore duty-free goods distribution qualifications (hereinafter collectively referred to as "relevant duty-free goods enterprises"), excluding goods prohibited from being traded or restricted for export by the State (see Attachment 1), cigarettes, and goods beyond the prescribed business scope of duty-free shops. Specifically, these refer to goods uniformly procured by relevant duty-free goods enterprises and sold in their affiliated port departure duty-free shops, downtown duty-free shops, and offshore duty-free shops in compliance with regulations.
(3) Bid-winning electromechanical products sold for use in international bidding construction projects financed by international financial organizations or foreign government loans (hereinafter referred to as "bid-winning electromechanical products"). The specific scope of lending institutions and bid-winning electromechanical products is provided in Attachment 2.
(4) Self-produced offshore engineering structures that are sold to Sino-foreign cooperative oil (gas) field exploitation enterprises and are subject to VAT on a physical basis. The specific scope of offshore engineering structures and Sino-foreign cooperative oil (gas) field exploitation enterprises is provided in Attachment 3.
(5) Goods sold to international transport enterprises for use on international conveyances. Specifically, these refer to goods sold by taxpayers to international transport enterprises for use on international transport vessels, and aviation food produced and sold by domestic aviation supply companies to domestic and foreign airlines for international flights.
(6) Water (including steam), electricity, and gas sold to taxpayers within special zones for consumption in the production of goods, provision of processing services, and repair and replacement services, and supplied to special zones without being declared to Customs (hereinafter collectively referred to as "water, electricity, and gas supplied to special zones").
Water, electricity, and gas supplied to special zones shall be declared for VAT refund (exemption) by the purchasing taxpayers in the special zones. Taxpayers in the zones who use such supplies for leasing or transferring factory buildings shall not declare VAT refund (exemption), and the input tax amount shall be transferred to costs.
(7) Newly manufactured containers declared to Customs, delivered to designated depots within the territory of China, and sold to overseas entities or individuals.
(8) Spacecraft and related goods delivered in orbit.
In-orbit delivery refers to the business activities in which spacecraft and related goods are launched into a predetermined orbit and then delivered for use by domestic or overseas entities or individuals.
Spacecraft and related goods include satellites, space probes, and other spacecraft and their components, parts, satellite payloads, satellite TT&C system equipment, software, facilities, etc.
(9) Goods used for overseas contracted projects, outbound investment, and foreign aid projects funded by preferential loans.
Unless otherwise provided in this Announcement or in other provisions issued by the Ministry of Finance and the State Taxation Administration, deemed exported goods shall be subject to the provisions applicable to exported goods.
3. Exported goods referred to in this Announcement include self-operated exported goods and entrusted exported goods.
(II) Cross-border sales of services and intangible assets.
1. The following services and intangible assets sold to overseas entities and fully consumed outside the territory of China:
(1) R&D service.
(2) Contract energy management service.
(3) Design service.
(4) Radio, film, and television production and distribution service.
(5) Software service.
(6) Circuit design and testing service.
(7) Information system service.
(8) Business process management service.
(9) Offshore service outsourcing business.
Offshore service outsourcing business includes information technology outsourcing service (ITO), technical business process outsourcing service (BPO), and technical knowledge process outsourcing service (KPO).
(10) Technology transfer.
The specific business activities involved in this Sub-item shall be implemented in accordance with the corresponding business activities in the Explanatory Notes on the Sale of Services, Intangible Assets and Immovable Property published by the Ministry of Finance and the State Taxation Administration. The specific scope of offshore service outsourcing business is provided in Attachment 4.
The term "fully consumed outside the territory of China" as mentioned in this Announcement refers to:
(1) The actual recipient of the service is located outside the territory of China, and the service is unrelated to goods, immovable property, or natural resources within the territory of China.
(2) The intangible assets are used entirely outside the territory of China, and are unrelated to goods, immovable property, or natural resources within the territory of China.
(3) Other circumstances stipulated by the Ministry of Finance and the State Taxation Administration.
2. International transportation services. Specifically, this refers to:
(1) Transporting passengers or goods from within the territory to outside the territory of China.
(2) Transporting passengers or goods from outside the territory into the territory of China.
(3) Transporting passengers or goods outside the territory of China.
3. Space transportation services refer to the business activities of launching spacecraft, such as satellites and space probes, into space orbit using carriers like rockets.
4. Outward repair and replacement services refer to the repair and replacement services provided for goods imported for re-export or for conveyances engaged in international transport.
II. VAT Refund (Exemption) Methods
For export business subject to VAT refund (exemption) policy apply, taxpayers shall adopt the tax exemption-credit-refund method or the tax exemption-refund method in accordance with the following provisions.
(I) Tax exemption-credit-refund method.
For export business, taxpayers are exempted from VAT at the export stage, and the corresponding input tax amount is offset against the VAT payable (excluding VAT taxable calculated according to the VAT collection-and-refund-upon-levy or VAT refund (or rebate) after levy, or simplified tax calculation methods). The uncredited portion shall be refunded. The applicable scope includes:
1. Export of self-produced goods and goods deemed as self-produced goods by manufacturing enterprises (the specific scope of goods deemed as self-produced goods is provided in Attachment 5).
2. Export of non-self-produced goods by designated manufacturing enterprises (the specific scope of such enterprises is provided in Attachment 6).
3. Cross-border sales of services and intangible assets by manufacturing enterprises.
4. Direct export of services or self-developed intangible assets by foreign trade enterprises, which shall be treated as manufacturing enterprises and subject to the tax exemption-credit-refund method together with their exported goods.
The term "manufacturing enterprises" as mentioned in this Announcement refers to taxpayers with production capacity; "foreign trade enterprises" refer to taxpayers without production capacity.
(II) Tax exemption-refund method.
Where foreign trade enterprises or other entities export goods or conduct cross-border sales of externally purchased services or intangible assets, VAT at the export stage shall be exempted, and the corresponding input VAT shall be refunded.
III. VAT Export Refund Rates
(I) Except for the VAT export refund rates explicitly determined by the Ministry of Finance and the State Taxation Administration based on the decisions of the State Council (hereinafter referred to as "refund rates"), the refund rate applicable to export business shall be the applicable tax rate. The State Taxation Administration shall publish the refund rates through the tax refund rate database in accordance with the above provisions.
Unless otherwise provided, the effective time of the refund rates for export business shall be determined as follows:
1. For exports declared to Customs (excluding exports from bonded zones and exports via bonded zones), the export date specified on the customs declaration form for exported goods shall prevail.
2. For exports not declared to Customs, the issuance date of the export invoice or ordinary invoice shall prevail.
3. For exports from bonded zones and exports via bonded zones, the exit date specified on the documents issued by Customs at the time of goods departure from the territory shall prevail.
(II) Other provisions on refund rates.
1. For export goods, services, and intangible assets purchased by foreign trade enterprises taxed under the simplified tax calculation method, or those purchased from small-scale taxpayers, the refund rates shall be the levy rate actually applied under the simplified tax calculation method or the levy rate applicable to small-scale taxpayers, respectively. Where special VAT invoices are obtained for the above export business, the refund rate shall be determined in accordance with the principle of applying the lower of the VAT rate (levy rate) indicated on the special VAT invoice and the refund rate applicable to the export business.
2. For outward repair and replacement services provided by taxpayers, the refund rate shall be the refund rate for the repaired and maintained goods; for goods exported after being retrieved from entrusted processing, and for goods exported after being retrieved from entrusted repair and replacement, the refund rate applicable to the processing or repair and replacement fees shall be the refund rate applicable to the exported goods.
3. For bid-winning electromechanical products; listed raw materials sold to taxpayers in special zones for production consumption after customs declaration and entry into special zones (hereinafter referred to as "listed raw materials," the specific scope of listed raw materials is provided in Attachment 7); water, electricity, and gas supplied to special zones; space transportation vehicles and related goods purchased for space transportation services, as well as launch and operation support services; and spacecraft and related goods delivered in orbit, the refund rate shall be the applicable tax rate.
When the State adjusts the refund rate for listed raw materials, the listed raw materials shall be subject to the adjusted refund rate from the date of adjustment.
Space transportation vehicles and related goods include rockets, space shuttles, and other space vehicles and their components, parts, and propellants.
Launch and operation support services include measurement and control, research and development, design, testing, inspection, supervision, space system integration services related to launch activities and in-orbit delivery; technology transfer, technical coordination, technical consulting, full life cycle services for spacecraft; orbit (frequency) application, consulting, and leasing services; cooperation, purchase, and leasing services for satellite payloads; space product transportation, space-related training services; exhibition and display of space product facilities and technology, and other related services.
(III) Where export business is subject to different refund rates, such export business shall be separately declared to Customs, separately accounted for, and separately declared for tax refund (exemption).
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