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Q&A Regarding Export Tax Refund (Exemption) (3)

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Q:
The classification and management category of export tax refunds for export enterprises in previous years were all classified as Class II. In May of this year, they were rated as Class IV export enterprises due to their tax credit rating of D-level. Currently, their tax credit rating has been restored to B-level. Can they still reapply for classification as Class II export enterprises?
A:
Sure. According to regulations, if taxpayers encounter situations of tax credit restoration, they can submit a written request to the tax authorities to re-evaluate their management category of export tax refund enterprises. Taxpayers who are re-evaluated due to reasons of tax credit restoration are not subject to the restriction of " class IV export enterprises cannot be classified as other management categories within 12 months from the date of evaluation". Therefore, it is possible to submit a written request to the tax authorities to re-evaluate the management category of export tax refund enterprises.

Q:
What does it mean by “lack of on-site verification” handling of the export tax refund (exemption)?
A:
The“lack of on-site verification” handling of the export tax refund (exemption) refers to the measures that, on the premise of controllable risks, based on existing regulations, for the first declaration of tax refund (exemption) as well as the first declaration of tax refund (exemption) after changing the tax refund (exemption) method that requires on-site verification and approval, different tax refund (exemption) limit standards are set according to different business types of different enterprises. The tax authorities shall go ahead reviewing and handling the tax refunds (exemptions) for the enterprise before the accumulated tax refunds (exemptions) declared by the enterprise exceed the set limit; After the accumulated tax refunds (exemptions) declared exceeding the set limit, the excess amount will be subject to on-site verification before being processed for tax refund (exemption).
The limit standard for the cumulative declared amount of tax to be refunded (exempted) is: 1 million yuan for foreign trade enterprises (including self-operated export business of foreign trade comprehensive service enterprises); 2 million yuan for production enterprises (including tax refund business entrusted by production enterprises); 1 million yuan for foreign trade comprehensive service enterprises that handle tax refunds on behalf.

Q:
What type of export tax refund (exemption) businesses are entitled to the “lack of on-site verification” handling of the export tax refund (exemption)?
A:
The export tax refund (exemption) business entitled to“lack of on-site verification” handling of the export tax refund (exemption) includes not only the export tax refund (exemption) declared by the enterprise for exporting goods and deemed export goods, but also the export tax refund (exemption) declared by the enterprise for providing processing, repair and maintenance services to the outside world, as well as the export tax refund (exemption) declared for zero tax rate cross-border taxable behaviours.

Q:
Do class IV export enterprises need to submit foreign exchange receipts when declaring export tax refunds (exemptions)?
A: Yes, foreign exchange receipts need to be submitted.

Q:
In October 2022, an export enterprise was unable to collect foreign exchange within the prescribed period due to changes in foreign commodity market conditions. Can export tax refund be declared under such situation?
A: Sure. For export goods that are subject to export tax refund (exemption) policies, if the company fails to receive foreign exchange within the prescribed period due to changes in foreign commodity market conditions, providing relevant certificates issued by the Chamber of Commerce or relevant exchange quotation information can be considered as the same as receiving foreign exchange for tax refund; If it is not possible to provide due to objective reasons, providing relevant proof materials from the importer can also be considered as the same as the collection for tax refund processing.

Q:
How should an export enterprise handle the inconsistency between the commodity code on the export declaration form and the adjusted commodity code due to the commodity code was adjusted by Custom?
A:
During the period between the declaration date on the export goods declaration form and export date, if the Custom adjusts the commodity code, resulting in inconsistency between the commodity code on the export goods declaration form and the adjusted commodity code, the tax refund (exemption) should be declared according to the commodity code listed on the export goods declaration form, and the "Corresponding Adjustment Table of Customs Export Commodity Code, Name, and Tax Refund Rate" and electronic data should be submitted at the same time.

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