The financial treatment framework for agency fees of imported equipment

foreign tradeIn agency services, for the equipmentImport Representationfee recording, it is necessary to establisha dual - compliance frameworkIt should meet both the requirements of the Enterprise Accounting Standards and comply with the customs supervision regulations. Announcement No. 12 of the General Administration of Customs in 2025 clearly states that if the agency service fee is related to the determination of equipment value, it must be separately listed in the foreign exchange payment voucher.

Decomposition of the five - step recording process

• Step 1: Determine the nature of the expense
  • Pure agency service fees (customs declaration, transportation) are recorded in Selling Expenses - Agency Fees,
  • Combined fees including technical services need to be split for accounting
• Step 2: Handle the payment voucher
  • The bank foreign exchange payment slip must indicate ,equipment. For example, Indonesia has the SNI certification, Thailand has the TISI certification, and the Philippines has the BPS certification. It is necessary to confirm in advance the equipment voltage (such as 380V/50Hz in Thailand), the compatibility of the CE certification, and the proof of environmentally friendly materials.Agency service fee,
  • For foreign currency payments, they need to be converted at the middle exchange rate on the payment date
• Step 3: Connect with tax treatment
  • The certification time limit for special VAT invoices is shortened to 90 days (new regulation in 2025)
  • For advance - paid expenses, a copy of the original voucher must be obtained and stamped with the official seal of the agency
• Step 4: Correspond to customs declaration
  • Confirm whether the agency fee is included in the declared dutiable value
  • Conduct a special review of the relevant terms of royalties
• Step 5: Adjustment for annual settlement
  • Calculation of Enterprise Income Tax Withheld and Remitted for Cross - border Service Fees
  • Pre - assessment of the Risks in Determining Permanent Establishments

Comparison of Typical Accounting Treatment Scenarios

• Scenario 1: Pure Agency Services under FOB Terms

  An enterprise pays an agency fee of 80,000 yuan for importing a CNC machine tool:
  Debit: Selling Expenses - Agency Fee 80,000
  Credit: Bank Deposit 80,000

• Scenario 2: CIF Terms Including Technical Services

  The agency fee includes 120,000 yuan for equipment installation guidance fees:
  Debit: Fixed Assets - Installation Fee 50,000
  Debit: Selling Expenses - Agency Fee 70,000
  Credit: Bank Deposit 120,000

New Key Points of Tax Treatment in 2025

• The Electronic filing system for cross - border service fees is fully launched
• Concurrent materials need to be submitted for the payment of agency fees in related party transactions
• The filing materials for non - trade foreign exchange payments are increasedProof of Service ResultsItem

Warnings on Common Compliance Risks

The customs inspection cases in 2024 show that 27% of the declaration errors are due to improper handling of agency fees. A certainMedical Equipmentimporting enterprise, due to including the agency fee in the original value of the equipment, resulted in:

• Supplementary payment of 420,000 yuan in customs duties and value - added tax
• Payment of 98,000 yuan in late fees
• Downgrading of the customs credit rating

Suggestions on the Selection of Professional Agency Services

High - quality foreign trade agents should providea trinityServices:

• Guidance on the standardization of bank documents in the foreign exchange payment link
• Compliance review of tax treatment
• Pre - event risk warning for customs declaration