Officially implemented on June 1st! The rules of the export tax refund game have completely changed. Foreign trade professionals must understand these three documents.

As a foreign trade boss, I will ask you three questions first:

Do you know how many documents are currently being managed for export tax rebates?

Do you know what 36 months overdue means?

Do you know how much the penalty is for tax fraud of 100,000 yuan and tax fraud of 5 million yuan?

If you cannot answer, you must read this article through.

On June 1, 2026, Announcement No. 5 of 2026 of the State Administration of Taxation officially entered the implementation cycle. But many people confuse one thing-the so-called new export tax rebates are actually not one document, but three, each of which handles different matters. Mixing up the source will directly affect your understanding of the policy.

One or three documents, each with a division of labor

The first: Announcement No. 11 of 2026 of the Ministry of Finance and the State Administration of Taxation-Management Policies.& nbsp; It stipulates which export businesses are subject to tax refund (exemption), exemption or taxation, as well as the tax basis, calculation method of exemption and refund, etc. It replaces Caishui [2012] No. 39 document that has been in use for many years.

Second: State Administration of Taxation Announcement No. 5 of 2026-Management Process.& nbsp; It talks about how to file, how to declare, which forms to submit, how to keep documents, and how to handle foreign exchange collection. It replaces Management Measures No. 24 of 2012.

Third: Announcement No. 2 of 2026 of the Ministry of Finance and the State Administration of Taxation-Administrative Tax Rate.& nbsp; Regardless of the tax refund rate, specific adjustments to photovoltaics and batteries will be implemented from April 1, 2026.

Remember the division of labor: 11 manages policies, 5 manages processes, and 2 manages tax rates.

Source: Policies and Regulations Library of the State Administration of Taxation

2. All filing forms are handled for all purposes, increasing efficiency by 55%

In the past, when filing export tax rebates, you had to fill out 5 forms and break your legs.

Now Announcement No. 5 has simplified the five filing forms into one "Export Refund (Exemption) Tax Filing Form", achieving universal processing of one form. Filing efficiency is expected to increase by 55%.

There are several time points to note for filing:

Before filing for tax refund for the first time, filing must be completed. If not, there will be no follow-up.

If there is any change in the filing content, an application for change must be filed within 30 days.

If you want to change the tax refund method (from exemption from tax refund to exemption from tax refund), you must first settle the original tax refund

Want to cancel your tax registration? Withdraw the export tax refund (exemption) for filing first

There are also three additional free channels for declaration channels: the national unified standardized electronic taxation bureau, the standard version of the single window for international trade, and the offline export tax refund declaration tool, which is paperless throughout the process.

Source: Full interpretation of the new export tax refund regulations in 2026, China-Shenzhen International Trade, 2026-05-28

3. 36-month hard period: overdue period will be regarded as domestic sales tax reimbursement

This is the most concerned change in this new regulation.

Under normal circumstances, export tax rebates should be declared from the month following the customs declaration and before April 30 of the following year. If you miss the normal period, you can make a supplementary report within 36 months from the date of customs declaration for export.

However, once it has not been declared for more than 36 months, the export will be directly regarded as domestic sales, and value-added tax and consumption tax will be paid in accordance with domestic sales regulations.

Several details that must be noted:

The 36-month period is only effective for exports after January 1, 2026, and the previous ones will follow the old rules.

It is a two-stage pattern of April 30 + 36 months of the following year, not 36 months at the beginning.

Many articles on the Internet write the consequences of overdue periods as payment of value-added tax + late payment fees, but the main body of the document only clarifies that tax payment is based on domestic sales, and late payment fees are inferred, subject to the caliber of the competent tax authority.

Don't think that you will relax after a long time. 36 months is a buffer for extreme situations. Efficient turnover is the key to saving taxes. Morning reports can be made as soon as possible.

4. The collection of foreign exchange will be kept for future reference and will no longer be submitted every time

This is a real change in the facilitation of Announcement No. 5: under normal circumstances, there is no need to attach foreign exchange collection materials when applying for export tax rebates, and the supporting materials can be kept for future reference.

There are only a few specific circumstances where collection documents need to be submitted:

Those who declare the tax refund after April 30 of the following year

Export enterprises were rated as four categories

Foreign collection materials have been found to be falsely used and have not been used for 24 months

However, it should be noted that general declarations do not require submission of foreign exchange collection materials, which does not mean that there is no need to collect foreign exchange.& nbsp; You must still collect the money that should be collected and the vouchers that should be kept, but you don't have to hand in every tax refund.

There is also another important change: the retention period of documents has been extended from 5 years to 10 years.& nbsp; Purchase and sales contracts, transportation documents, entrusted customs declaration documents, etc., shall be sorted and retained within 15 days after applying for tax refund, and the retention period is ten years. Enterprises can choose paper, imaging or digital storage methods, and no longer force paper.

5. Classification of tax fraud penalties: The difference between 100,000 and 5 million is not just the number

Announcement No. 5 significantly increases the penalties for fraudulent export tax rebates, and the classification is clear:

The amount of tax fraud is less than 100,000 yuan: the right to refund taxes will be suspended for half a year to one year

Tax fraud of 100,000 to 500,000: stop tax refund rights for one to one and a half years

Tax fraud of 500,000 to 5 million yuan: stop tax refund rights for one and a half to two years

Tax fraud of more than 5 million yuan: stop tax refund rights for two to three years

If a crime is constituted: directly transferred to the public security organ for criminal responsibility

At the same time, in 2025, the tax department inspected 76,000 enterprises suspected of falsely issuing tax fraud, found that 3.324 million value-added tax invoices were falsely issued to the outside world, and verified that defrauded and illegal export tax rebates exceeded 10 billion yuan. nbsp; In 2026, multi-department data sharing and joint crackdowns will be further deepened to severely crack down on professional, networked and cross-regional illegal criminal gangs.

Don't take chances. The fourth phase of gold tax + customs + foreign exchange data is directly connected to the Internet, and the penetration inspection is conducted. The disintegration of the four streams is a clear sign.

Source: Supervision in the field of export tax rebates will continue to be strengthened in 2026, Sohu, 2026-06-01

6. Adjustment of tax refund rate: photovoltaics are cancelled and battery ladder is lowered

This part comes from Announcement No. 2:

Photovoltaic products: Starting from April 1, 2026, the VAT export refund will be cancelled, and the tax refund rate will be reduced to 0%

Battery products: From April 1 to December 31, 2026, the tax refund rate will be reduced from 9% to 6%; from January 1, 2027, it will be completely cancelled

For a photovoltaic boss, the tax refund profit column in the quotation sheet must be directly deleted, and the finance department must immediately calculate the cost increase.

For battery bosses, 2026 is the last window period. Those who can confirm their income before 2027 should hurry up.

The policy background is very clear: the state no longer uses export tax rebates to support industries that are already internationally competitive but have entangled low-price competition, and guides the shift to high-quality development.

Source: 2026 new export tax refund rules: 0% for photovoltaics, only 6% for batteries, Zhongrui Guobang Tax Agents Office, 2026-05-29

7. Four action suggestions for foreign trade enterprises

First, clarify the tax rate destination of products.& nbsp; Compare the tax refund rate library and the annex to Announcement No. 2 to confirm the tax refund rate corresponding to the HS code. In particular, photovoltaic and battery companies must calculate the cost difference around April 1.

Second, set the 36-month line well.& nbsp; Establish a ledger for export customs declaration, voucher collection, collection of foreign exchange and declaration to avoid delay causing the entire export to be regarded as domestic sales tax.

Third, make good use of the convenience of retaining foreign exchange collection for future reference, but don't relax in providing evidence.& nbsp; Generally, there is no need to submit foreign exchange collection materials for general declarations, but overdue declarations and four types of enterprises still need to be provided, and they must be kept in a regular manner at ordinary times.

Fourth, documents are managed according to a 10-year standard.& nbsp; No matter which storage method is chosen, prepare a catalog and indicate the storage method, so that you can check with the tax authorities at any time.

final analysis

The new export tax refund policy in 2026 appears to relax the application time, but in fact it uses big data to strengthen the control of compliance and foreign exchange collection.

It is more convenient to declare, but the investigation is more strict.& nbsp; These two sentences are the entire logic of the new regulations.

For formally operating export enterprises, the new regulations bring more convenience-one form for filing, the collection of foreign exchange will be kept for future reference, and the entire process will be paperless.

But for those who want to exploit loopholes, this method will plug every loophole tightly.

Compliance is the best talisman.& nbsp; Tax refunds are not calculated, they are calculated through compliance.

Source: Leading the way to the sea by Gaoshen's car

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