Export VAT Refund Consistency & Compliance Advisory

Helping foreign-invested enterprises build defensible, auditable export VAT refund logic in China

1 Why Export VAT Refund Applications Get Rejected

Many export VAT refund issues are not caused by the transaction itself, but by inconsistencies that cannot be clearly explained to systems or tax authorities:

• Invoice and customs declaration descriptions do not fully match

• Product models or symbols differ across documents (even a single symbol or abbreviation can trigger system alerts)

• Commercial invoice descriptions cannot be directly matched to the customs declaration

• Collection amounts differ due to bank fees or foreign exchange  (FX) fluctuations

• No unified internal rules across finance, customs, and operations teams

These issues often result in:

• VAT refund rejection or suspension

• Repeated document revisions, which further increase compliance risks

• Inability to provide clear explanations to tax authorities or overseas headquarters (HQ)

2 Our Core Principle

Export VAT refunds do not require character-by-character identity.

They require a consistent logic proving the same underlying export transaction.

What gets rejected is not punctuation 

but the absence of a stable, consistent, and auditable explanation framework.

3 What We Do (Not Document Editing)

① VAT Refund Consistency Risk Assessment

We first help enterprises assess:

• Whether current inconsistencies are clerical errors, descriptive differences, or substantive discrepancies

• Which documents can be reasonably explained

• Which scenarios are not recommended for VAT refund application

This helps enterprises avoid "high-risk declarations" at the source.

② Invoice–Customs–Collection Consistency Design (Core Service)

We assist enterprises in establishing clear rules:

• Fields that must be strictly consistent

• Fields where differences are acceptable with proper explanation

• Mapping logic between commercial invoice descriptions and customs classification

• Unified rules for models, specifications, abbreviations, and symbols

The goal is long-term regulatory defensibility, not cosmetic alignment.

③ Pre-Transaction Coordination Rules

For common operational questions such as:

“Can customs declarations follow the invoice description?”

We help define:

• When invoice-based declaration is acceptable

• When customs classification must prevail

• Which adjustments are compliant and which carry high risks

So teams operate based on clear rules, not ad-hoc judgment.

④ Regulatory Review & HQ Explanation Pack

We prepare comprehensive materials to support your needs:

• VAT refund consistency explanation templates

• Difference explanation logic (bilingual: Chinese & English)

• Internal process flowcharts and responsibility division

• Exception handling guidelines

These materials support tax authority inquiries, audits, and overseas HQ reviews.

4 Who This Service Is For

• Foreign-invested enterprises (FIEs) operating in China

• Exporters of technology, equipment, and components

• Companies frequently challenged on VAT refund consistency

• China subsidiaries required to provide clear, auditable reports to overseas HQ

5 What We Do Not Provide

• Document alteration

• Cosmetic alignment solely for refund purposes

• VAT refund filing agency services

Our focus is on compliance logic design and proactive risk control.

6 Disclaimer

This service provides general compliance and risk management guidance based on practical experience. It does not constitute legal, tax, or customs advice for any specific transaction.

7 CTA | Contact Us

We do not make decisions for you; we only help you clarify facts and risks.

Phone : 400 800 7472

Email : info@rtfcpa.com