Invoice-free exemption or export VAT refund: which applies to me?
📋 Direct Answer
The split is simple once you look at your invoices. With supplier VAT invoices in hand, the general export refund route is open: declare the goods out and claim a refund at the rate set for your HS code in the official refund rate library. Without valid purchase documents, exports from a comprehensive pilot zone can take the VAT and consumption tax exemption under Caishui [2018] No. 103, in force since 1 October 2018. No VAT is owed on the export, but there is no refund either. Exemption is not tax planning; it only covers VAT and consumption tax on the exported goods. Check the three exemption conditions below before relying on it.
HS Code Lookup
Open HS Code Lookup →Export refund fraud carries criminal liability. The exemption route is safer on paper but still requires real exports and honest records.
False refund claims, such as inflated invoices and fabricated exports, are prosecuted; exemption claims built on fake platform records can be clawed back with penalties.
🛡️ Prevention Steps
- ✓Only claim refunds against genuine supplier invoices and real shipments
- ✓Keep platform registration entries consistent with actual export data
- ✓Keep documents for the retention period your local authority requires
Item by Item
InfoExport VAT refund: for sellers with invoices
- 1Collect VAT invoices from suppliers that match the exported goods and values
- 2Declare the goods out through customs with the right HS code
- 3Look up the current refund rate for your HS code in the e-tax bureau refund-rate query
- 4File the refund claim with the tax authorities and keep invoices, declarations and payment records aligned
InfoInvoice-free exemption: for pilot-zone sellers without purchase documents
- 1Register in a comprehensive pilot zone and log export date, goods, unit, quantity, unit price and amount on the local online service platform
- 2Clear the goods at the pilot zone's local customs as e-commerce exports
- 3Confirm the goods are not on the list whose export refund or exemption has been withdrawn
- 4Treat exemption as VAT/consumption tax only; other taxes follow their own rules
InfoThe decision path in practice
- 1Have supplier VAT invoices? → price in the refund route and verify the current rate for your HS code
- 2No invoices but registered in a pilot zone? → check the three exemption conditions one by one
- 3No invoices and outside a pilot zone? → neither route is clean; weigh moving sourcing, joining a pilot zone, or professional advice
- 4Whichever path you take, keep the customs declaration, transaction and payment records consistent
Common Mistakes
❌ Reading "exemption" as every tax is covered
💥 Consequence: Seller budgets zero tax cost and is surprised by taxes outside VAT and consumption tax
✅ Fix: The exemption in Caishui [2018] No. 103 covers VAT and consumption tax on the exported goods; nothing more
❌ Claiming a refund with mismatched invoices
💥 Consequence: Claims get rejected or escalate into audit; invoice-value mismatches are a classic trigger
✅ Fix: Align invoice goods, quantities and values with the customs declaration before filing
❌ Assuming exemption applies outside a pilot zone
💥 Consequence: Registration in a comprehensive pilot zone is one of the three conditions; without it the exemption does not apply
✅ Fix: Verify your entity's registration location against the pilot-zone list before relying on exemption
Seller Paths
Next Steps
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Related Questions
Sources
- • Caishui [2018] No. 103 (invoice-free exemption)
- • Caishui [2012] No. 39 (VAT and consumption tax policies for exported goods and services)
- • Shanghai Tax Bureau export refund rate query
Disclaimer: This page is for informational purposes only and does not constitute legal or tax advice. Consult a professional for your specific situation.