In the past summer, China’s Ministry of Finance (MoF) and the State Administration of Taxation (SAT) jointly issued the “Notice Regarding VAT and CT Policies for Export Goods and Services (caishui [2012] No. 39.”   The SAT subsequently issued SAT Announcement [2012] No. 24, in an attempt to clarify the VAT and consumption tax policies for exported goods and services. 

Some of the key points of Circular 39 and Announcement No. 24 are as follows:

1. The previous stipulation that a newly-established enterprise is not eligible for tax refund within 12 months of establishment has been eliminated.

2. Scope of goods that can be deemed as so called “self-manufactured” to qualify for export tax refund/exemption has been expanded.

3. Scope of good that are subject to tax has been narrowed.

4. Deadline to claim export tax refund/exemption has been extended. Now an enterprise has until April 30 of the year following to apply for refund/exemption.