Paying for export, the hidden disease of the industry under the guise of convenience

In foreign trade fields such as textiles, "paying for export" was once the "unspoken rule" of some companies: companies that lack export qualifications or want to simplify the process purchase complete customs declaration materials from companies with legal export rights and complete the export declaration of goods in the name of the other party. This model is particularly common in the export of low-value, low-tax products - because the export tax rebate for such products is low or even non-existent, companies can bypass formal links such as qualification application and process approval by paying for export, reduce human and material investment, and reduce operating costs in the short term.

But there are huge hidden dangers behind the convenience. In essence, paying for export is a "borrowing right operation", and the actual right of goods is separated from the customs declaration subject. Companies often conceal export income by forging or purchasing customs clearance documents, which directly leads to the loss of national value-added tax, corporate income tax and additional taxes and fees. If it involves acts such as false VAT invoices, the person in charge of the company may even violate the Criminal Law and constitute tax evasion. What is more worthy of vigilance is that, unlike small commodities, if bulk products such as steel are involved in the purchase order export, due to the huge amount, not only will the risk of tax loss increase exponentially, but it will also disrupt market prices, undermine the balance of supply and demand, and cause a serious impact on the foreign trade environment of fair competition.

The new regulations are unveiled, and the binding clauses of the 17th announcement are interpreted

The core deterrent power of the 17th announcement of the State Administration of Taxation is concentrated in the clear provisions of Article 7: Enterprises that export goods by agents (including market procurement trade, foreign trade comprehensive services, etc.) must simultaneously report the basic information and export amount of the actual entrusted exporter when making advance payment declarations, and the actual entrusted exporter is clearly defined as the "actual production and sales unit of the exported goods." This requirement completely breaks the operating space of "blurring the owner's information" in the purchase order export, and brings the source producer of each export business into the precise supervision vision of the tax authorities.

The new regulations also set up a strict accountability mechanism. If the agency fails to accurately report the actual entrusting party information, the export business will be directly identified as the self-operated business of the agent, and the agent shall bear the full amount of corporate income tax on the corresponding export amount. This means that both the agent who provides the customs declaration documents and the enterprise that actually pays for the export must bear clear tax responsibilities for violations. The substantial increase in regulatory costs has fundamentally cut off the gray interest chain on which the export of bills depends for survival, leaving no loopholes for "exporting by borrowing rights" at the policy level.

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