The Invoice Dilemma in Agency Import Business

2025 Edition of the "Customsimport and exportAfter the implementation of the "Goods Declaration Management Measures," a certainMedical EquipmentDue to a misunderstanding of the invoice issuance rules, the importer caused a CT device worth $3.8 million to be detained in the bonded area for 23 days, incurring additional storage costs exceeding 120,000 yuan. This case highlights the professionalism and importance of invoice issuance rules for agency-imported equipment.

Rules for Determining the Responsible Entity for Invoice Issuance

According to the "Model Text for Cross-Border Trade Service Agreement (2025 Revised Edition)," the entity responsible for issuing invoices shall be determined based on the following comprehensive factors:

• The contracting party of a trade contract: Is the actual purchaser consistent with the contracting party?
• Fund payment path: Will the payment flow through the agency company's account?
• Customs declaration entity: The "Consignee" field in the customs declaration form.
• Value-added tax (VAT) deduction chain: The correspondence between tax payment certificates and invoices

Invoice Processing Under Different Trade Models

• Self-operated import model:
  • The importing enterprise directly issues a proforma invoice.
  • Please provide the foreign exchange purchase and payment voucher filed with the State Administration of Foreign Exchange.
• Proxy Pattern:
  • The agency issues an invoice for service fees.
  • The equipment invoice shall be issued by the actual user.
• Bonded zone import model:
  • Suspend the issuance of special VAT invoices
  • The tax invoice must be supplemented upon exiting the zone.

Common operational error warnings

• Mistakenly believing that the agency must issue an invoice for the equipment.
• Confusing the validity of a pro forma invoice with that of a special VAT invoice
• Neglecting the invoice remark requirements for cross-border service trade
• Incorrect use of the obsolete 2018 version invoice template

Key Points for Tax Processing in 2025

According to Announcement No. 1 of 2025 from the Ministry of Finance, special attention should be paid to the agency import of equipment:

• Withholding and remitting VAT requires a separate tax payment split certificate to be issued.
• Cross-border RMB settlement invoices must be marked with the "CIPS" identification code.
• E-invoices must be simultaneously uploaded to the Single Window system.
• The equipment commissioning fee shall be itemized separately from the equipment cost.

Typical dispute case analysis

Case 1:An automobile manufacturer entrusted an agent to import a production line equipment worth 20 million yuan. Due to the agent's incorrect issuance of the equipment invoice, the manufacturer was unable to deduct the input tax. The issue was ultimately resolved by re-signing a tripartite agreement.

Case 2:Medical device importers correctly adopted the "dual-header" customs declaration model, with invoices issued directly by the actual end-users, saving 15 working days in tax processing time.

Four-Step Compliance Operation Method

1. Sign a clear "Tripartite Rights and Responsibilities Confirmation Agreement".
2. Indicate the actual end user in the "Remarks" column of the customs declaration form.
3. Adopt the "one vote, two points" system for issuing invoices.
4. Establish an electronic invoice tracking management system

It is particularly noteworthy that the newly implemented "Intelligent Document Review System" by the General Administration of Customs in 2025 has achieved the automatic verification function for invoice information. Enterprises must ensure that the consistency rate among the customs declaration form, invoice, and contract exceeds 98%; otherwise, it may trigger a manual review process.