To help foreign companies with export tax rebate declarations, the following are answers to frequently asked questions.

Q1: As an export-oriented enterprise with substantial export volume, we often receive record documents, like the ocean bill of lading, in photographic format. Is it permissible for our company to maintain these records in this format?

A1: Yes. Regulatory guidelines allow your company to preserve record documents related to export tax refunds (exemptions) in either paper, photographic, or digital formats, depending on your operational preferences.

Regulatory basis: Refer to Article 2 of the Announcement by the State Taxation Administration on Further Facilitating the Processing of Export Tax Refunds and Promoting the Stable Development of Foreign Trade (Announcement No 9 of the State Taxation Administration in 2022).

Q2: Over the years, our export enterprise has always been classified under Class II for export tax refund management. However, following a downgrade to a tax credit rating to D in May, we were reclassified as a Class IV export enterprise. Given that our tax credit rating has now been upgraded to B, are we eligible to request reclassification to a Class II export enterprise?

A2: Yes. Should a taxpayer's tax credit rating improve, they are entitled to formally request a reevaluation of their export tax refund enterprise management category from the tax authorities. Taxpayers seeking reevaluation following a tax credit improvement are exempt from the rule preventing Class IV export enterprises from changing their management category within 12 months of the category assessment.

Regulatory basis: See Article 1 of the Announcement by the State Taxation Administration on Further Facilitating the Processing of Export Tax Refunds and Promoting the Stable Development of Foreign Trade (Announcement No 9 of the State Taxation Administration in 2022).

Source: Shanghai Municipal Commission of Commerce