What is an export tax rebate letter? Export tax rebate letter inquiry review

When a tax refund enterprise is handling a tax refund, if the tax bureau's review system prompts that there are specific doubts, the tax bureau will ask the enterprise to fill out a self-examination form and submit relevant voucher information, and then review the information, interview the enterprise or conduct an on-site inspection to confirm whether the export business is real. If there are doubts that cannot be ruled out, the tax bureau will send the information to be investigated to the tax bureau in the place where the enterprise's supplier is located through the letter inquiry system and ask it to assist in the investigation. After receiving the investigation letter, the supplier's tax bureau will contact the supplier to confirm and reply. The purpose is to rule out whether the enterprise has cheated on taxes.

Letter sending procedure

According to the "National Taxation Bureau Export Rebate (Exemption) Tax Management Work Specification (Version 2.0)" (Tax General [2018] No. 48), the taxation authorities responsible for export tax rebates can only issue letters if, when reviewing the tax refund (exemption) declared by the exporting enterprise, there are audit doubts that cannot be eliminated through desk analysis and other means. At the same time, according to the current export tax refund (exemption) management regulations, "documents and information are complete" before declaring tax refund (exemption). Special value-added tax invoices (paper or electronic data) must be provided when declaring tax refund exemption.

Situations that may lead to a letter of inquiry

According to the requirements of the Letter Inquiry Management Measures, the following situations may lead to the tax authorities sending letters for verification:

1. Export business involves early warning information from the State Taxation Administration, including export enterprises warned by the State Taxation Administration, supply enterprises warned by the State Taxation Administration, and export commodities warned by the State Taxation Administration.

2. Providing clues of suspected export tax rebate fraud within the tax system.

3. Departments outside the tax system provide clues of suspected fraudulent export tax rebates.

4. Both the exporting enterprise and the supplying enterprise are enterprises of concern and export commodities of concern.

5. Pay attention to the first time that the enterprise exports the goods of interest.

6. The exporting enterprise purchases the commodities of concern from the enterprise of concern for export for the first time.

7. The following circumstances exist and the written reasons with the official seal of the exporting enterprise are insufficient:

1. The cost of foreign exchange for export goods is higher than the reasonable upper limit.

2. The export of commodities of concern, and the monthly increase in the export volume of the commodities of concern exceeds 20% or the export unit price exceeds 10% compared with the last declaration.

3. The export commodity is of concern, and the purchase unit price of the commodity of concern exceeds 10% compared with the last declaration.

4. Cross-border trade RMB settlement business is found to be abnormal after analysis.

8. There is an obvious discrepancy between two or more of the following items: the location of the supplier, the place of shipment of goods, the customs declaration port, the departure port, the exporting country, the mode of transportation, etc.

9. The exporting enterprises that are exporting non-traditional commodities for the first time and are cross-category commodities do not have sufficient written reasons with official seal.

Depending on the doubts that arise during the tax authorities' audit, the following situations may also result in the tax authorities sending letters for verification:

(1) For export business where the goods are purchased from the same supplier, the cumulative tax refund amount declared for six consecutive months exceeds RMB 500,000 and the following conditions are met at the same time:

a. The exporting enterprise is a general risk exporting enterprise;

b. The general risk level of the supplier is level 2 or above;

c. The general risk level of exported goods is above level three.

(2) Where the company purchases general risk commodities from new suppliers and the cumulative tax refund amount declared exceeds RMB 500,000 within 6 consecutive months from the date of the first declaration.

(3) For export of general risk commodities, the tax refund amount declared this month exceeds RMB 500,000 and the month-on-month increase exceeds 100%.

(4) Export enterprises that export general risk commodities across commodity categories and whose cumulative tax refund claims for six consecutive months reach RMB 500,000 or more, and whose cumulative tax refunds for general risk commodities purchased from the same supplier exceed RMB 100,000.

(5) Where a comprehensive foreign trade service enterprise applies for a tax refund on its behalf, the manufacturing enterprise that entrusts it to handle the tax refund has export commodities in multiple categories.

(6) Other enterprises specified by the State Administration of Taxation.

Production enterprises that entrust tax refund agencies to handle tax refunds are deemed to be supplier enterprises of comprehensive foreign trade service enterprises. If they meet the above conditions, they will be the subjects of letter investigation.

References

• 1. Measures for the Administration of Tax Inquiry on Export Goods: State Administration of Taxation