Effective Date + Legal Basis
Leveraging the Golden Tax Phase IV system, tax authorities across China will begin fully automated cross-checking of the invoice remarks column in export tax refund reviews starting June 1, 2026. All newly declared export shipments are recommended to follow the specifications outlined in this article to avoid refund delays.
This is not a brand-new regulation, but rather a nationwide standardization and stricter enforcement of existing rules (such as SAT Announcement No. 35 [2017] and various local pilot requirements) under the Golden Tax Phase IV “digital tax governance” framework. Major exporting regions, including Zhejiang, Guangdong, and Jiangsu, have already aligned their requirements.
Four Major Consequences of Incorrect Remarks
Four Major Consequences of Incorrect Remarks (Must-Read):
If the remarks information does not match the customs declaration, contract, or bill of lading, or if key fields are missing, the tax refund system will reject the application. The invoice must be voided and reissued, delaying refunds by an average of 1–3 months.
Under Article 9 of the Provisional Regulations on VAT, non-compliant invoices cannot be used as pre-tax deduction vouchers. Corporate income tax deductions will be disallowed, potentially resulting in an additional 25% tax liability.
Remarks anomalies easily generate “red flags” in the tax refund system, causing refund processing to halt. Companies may be required to provide written explanations or supporting documents, severely delaying refund efficiency and increasing the likelihood of being selected for a tax audit.
Persistent non-compliance or submission of false information, in accordance with Article 64 of the Tax Collection and Administration Law, may result in fines of up to RMB 10,000. Where tax loss occurs, fines can range from 50% to 5 times the underpaid tax amount.
Correct Filling Standards for the Remarks Column (Template + Example)
1. Core Principles
- ▸ Fill consecutively (no line breaks), with no spaces, no abbreviations, and no alterations.
- ▸ Information must be 100% consistent with the customs declaration, export contract, bill of lading, and foreign exchange receipt confirmation.
- ▸ Applies uniformly to all trade methods (general trade, processing trade, cross-border e-commerce, etc.).
2. Mandatory Fields (None May Be Omitted)
| No. | Field | Requirement |
|---|---|---|
| 1 | Business identifier | Start with Export Business (four Chinese characters, fixed format) |
| 2 | Contract information | Contract No.: XXX (must match the “Contract Agreement No.” on the customs declaration) |
| 3 | Amount information | Foreign currency amount: XXX; Currency: XXX (e.g., USD, EUR – must match the customs declaration) |
| 4 | Exchange rate information | Exchange rate: X.XXXX (use the central parity rate on the export date or the 1st of the month, 4 decimal places) |
| 5 | Customs declaration information (required if available) | Customs Declaration No.: XXX |
| 6 | Logistics information (recommended) | Bill of Lading No.: XXX (if multiple B/Ls exist, fill the master B/L number or note “see B/L for details”) |
3. Standard Filling Template (Example for CIF Transaction)
*Note: The invoice “Amount” field should show the CIF RMB total price = 16000 × 7.1234.
4. Common Mistakes to Avoid
- ✗ Omitting the Export Business identifier
- ✗ Currency abbreviation error (e.g., “USD” → “US”)
- ✗ Amount inconsistent with the customs declaration
- ✗ CIF price invoiced without FOB amount in the remarks column
- ✗ Information split across multiple lines (must be written as one continuous line).
Other Key Invoicing Reminders
Must be a VAT general invoice (including electronic general invoice). Special VAT invoices are not permitted.
- ▸0% for tax refund / zero-rated transactions
- ▸Tax Exempt for exempt transactions
- ▸Applicable standard rate for taxable transactions
Unit price and total amount must be in RMB (after foreign currency conversion).
For overseas companies, it is recommended to provide both the standard Chinese translation and the full English name to avoid system parsing errors caused by special characters.
Urgent Action Checklist (Complete Before June 1)
Update invoicing system templates with a fixed remarks column format to eliminate manual entry errors.
Organize contract, customs declaration, and bill of lading information to ensure 100% alignment with invoicing data.
Review pending invoices for late May shipments and prepare in advance to avoid rework starting June 1.
Educate finance, operations, and customs declaration teams on the filling standards to eliminate human errors.
Export business is all about details. Compliance is the bottom line.
Though small, the remarks column is a critical checkpoint for tax refunds. Strictly follow the new standards starting June 1 – don’t lose big over a minor oversight.
Post time: May-27-2026