There are various ways to cheat export tax rebates, but it is difficult to disguise and change the nature of tax cheating, and once the amount of cheating export tax rebates reaches the legal prosecution standard, which is in line with the criminal composition stipulated in Article 204 of the Criminal Law, criminal liability will be investigated in accordance with the crime of cheating export tax rebates. At the same time, in order to achieve the purpose of cheating the state tax rebate, the tax fraud case may also involve the situation of forging the flow of funds and invoices, and thus may be suspected of the crime of false VAT invoices and other crimes. Therefore, the tax-related risks faced in the case of fraudulent export tax rebates are extremely high, and taxpayers should familiarize themselves with the potential risks common to the export tax rebate business and adopt effective defense strategies to safeguard their legitimate rights and interests.

I. Introduction of the case

(I) the case situation

During the period from December 2017 to June 2018, Defendant Wang Mougang, after learning that the Yangpu Economic Development Zone (hereinafter referred to as Yangpu) in Hainan Province has preferential export tax rebate policies, successively registered three companies A, B and C and obtained the qualification of general taxpayers, and the actual control of the three companies was Wang Mougang.After the establishment of the three companies A, B and C, with the help of Zheng Moubin and others, Defendant Wang Mougang Employed Yang Moyan, Wu Mouxia, Chen Mou concubines and other people to handle the export tax rebate business, of which Wu Mouxia, Chen Mou concubines for the A, B, C three companies accountant, Yang Moyan as a staff member, Defendant Wang Moujun is responsible for the other work of the three companies. Defendant Wang Mougang regularly paid Defendant Wang Moujun and Yang Moyan, Wu Mouxia, and Chen Chao Concubine.

During the period from June 2018 to September 2021, Defendant Wang Mougang privately exchanged U.S. dollars for foreign exchange with Zhu Moufeng and others when no real export trade business occurred in the three companies A, B, and C. Wang Mougang, through his or Wang Mouhong's bank account, first credited funds to Zhu Moufeng and others, and then asked Zhu Moufeng and others to remit U.S. dollars from Hong Kong companies, such as JC Company, to the A, B, and C Three companies account, and A, B, C three companies received the dollar foreign exchange settlement into RMB, and then transferred to Jiangxi Wanzai County Y Textile Factory, Wanzai County Z Textile Factory and other more than 20 upstream "supplier enterprises", used to fake the flow of funds, the formation of A, B, C three companies received JC and other companies foreign goods, and payment to the Jiangxi Wanzai County Y Textile Factory and other companies to buy goods of the illusion. A, B, C three companies to buy goods, in Jiangxi Wanzai County Y Textile Factory and other upstream "supplier enterprises", the same day or the next day through the intermediary account immediately to the same amount of money back to Wang Mougang, Wang Mouhong's bank account to realize the return of funds.

In the case of knowing A, B, C three companies did not occur real export trade business, the defendant Wang Moujun in the defendant Wang Mougang under the instruction of the defendant, will be received by Wang Mougang arranged for others to send from Hebei Province to Hainan's purchase and sales contracts, invoices, funds flow, false shipping bills of lading and customs declaration and other false export tax rebate materials, to A, B, C three companies accountant Wu Mouxia, Chen Mou concubines, etc. to the name of A, B, C three companies to A, B, B, C, C, C, B, C, C, C and C companies to the bank account. The three companies A, B and C submitted the materials to the Export Tax Refund Department of the State Administration of Taxation of Hainan Province to declare the export tax refund in the name of A, B and C companies. After the approval of the Hainan Provincial State Tax Bureau, the tax rebate amount was transferred to A, B and C companies through the State Treasury Payment Bureau. Defendant Wang Mougang flowed through the false purchase and sale of goods through intermediate accounts, and eventually part of it flowed into Defendant Wang Mougang's own and Wang Mouhong's bank accounts, and was used by Wang Mougang to return bank loans, return private loans, and pay the salaries of employees of companies A, B, and C and for personal consumption. From June 2018 to 2020, the export tax rebates fraudulently obtained by the three companies A, B and C by way of false export declarations and provision of false filing documents totaled 396,182,234.33 yuan.

(II) Focus of dispute: whether there is a real transaction of goods

Wang Mougang and his defense proposed: the existing evidence is not enough to prove that the company involved in the tax rebate goods are fake exports. And submit "i-tracking network" query information, according to the website information shows that A company, C company customs clearance of goods screenshots can prove that the two companies involved in a total of 30 single customs declaration of goods exported show that has been customs clearance of exports, and customs declaration number and packing number, bill of lading number, shipping company and A, C company to apply for a tax rebate provided by the number of the same! The total amount of tax refund involved in this part is 1680643.9 RMB. In addition, according to the Enterprise Credit Information Publication Report, it proved that the upstream 27 supplier companies had completed the deregistration, which indicated that the 12 companies had completed the tax verification and paid the owed taxes, and the fact of deregistration indicated that the taxes involved in the VAT invoices issued by the above enterprises for the three companies involved in the case had already been paid, and at the same time confirmed that the determination of the amount of the fraudulent obtainment without deducting the paid taxes was wrong.

The Haikou Municipal People's Procuratorate is of the opinion that "i-tracking network" is a website focusing on providing door-to-door logistics information tracking of water transport containers, which is used to inquire about the transportation information of containers from the entry and exit of gates, arrival and dispatch, customs release, loading and unloading of ships, departure of ships from the port, sea transit, arrival at the port of destination, pick-up of the cargo, etc. The website can know in real time where the goods are and whether they are in the right place. You can know in real time where the cargo is, whether it is cleared or not, customs release time, customs declaration number and other information. Detailed information of the goods such as goods, consignee unit, shipping unit and other key information related to this case can not be reflected. Therefore, it cannot be proved that the goods carried on the waybill have relevance to this case. At the same time, whether the 12 upstream companies to clear the tax paid in the case and whether the upstream companies and the three companies involved in the case have a real trade and no relevance, and the group of evidence is only business registration information, can not reflect the 12 upstream companies complete and real tax information.

(III) The Court's Opinion

The court adopted the Haikou city people's procuratorate point of view, and combined with the evidence of the case, make the following decision: ZhengMouBin and other people's testimony can confirm that A, B, C three companies are in WangMouGang dominated by WangMouJun's participation in the establishment of the registration. Wu Mouxia, Chen Mou concubine, Yang Mouyan and other people's testimony and Wang Moujun's statement can confirm that Wang Mougang is the actual controller of the company, Wang Moujun is responsible for the coordination of the company's daily affairs, to assist in dealing with the tax rebate affairs. Zhu Moufeng's testimony and the company's foreign exchange account water and related bank water and other evidence, can confirm that the company under its control and the company has no actual trade transactions, it should be Wang Mougang's request to the company is the two sides of the transfer of foreign exchange transactions. Hainan Provincial State Tax Bureau Inspection Bureau issued by the relevant documentary evidence and a bedding company in Shenzhen, an international freight forwarding company issued by the situation, witness testimony and other evidence can confirm that A, B, C three companies fake other companies documents, to false export, provide false filing documents and other means of fraudulent export tax refunds. Wang Mougang, Wang Mouhong, upstream supplier enterprises and other companies of the bank water can confirm that Wang Mougang asked Zhu Moufeng and others to remit U.S. dollars from overseas companies to the accounts of the three companies A, B, C, and instructed Wang Mouhong and others to remit the received U.S. dollars into RMB and transfer it to the upstream selling enterprises to form a flow of funds, which was used for fictitious export trade. After the tax refund arrived, the money flowed into the account controlled by Wang Mougang through the intermediary account. Later, Wang Mougang used it to return loans, loans, pay salaries, personal consumption, investment and purchase of real estate and other purposes.

Accordingly, the court ruled that the criminal facts alleged by the public prosecution authorities are clear, the evidence is true and sufficient, the charge is established, the defendant Wang Mougang, Wang Moujun violated the state's laws and regulations, endangered the state's tax collection and management, by means of false export declaration, cheated the state export tax rebate, amounting to 39618234.33 yuan, the amount is particularly huge, his behavior has constituted the crime of cheating export tax rebate.

II. Tips on potential tax risks of export tax refund business

In addition to the above cases, due to the differences of foreign trade enterprises in exporting goods, business model, operation mode, etc., the tax risks arising from them are also diversified, and the author hereby combines this case with the typical cases of tax fraud published by China Referee Instruments Network to sort out the potential common tax risks in the field of export tax rebate for the benefit of the readers:

(I) Tax-related Risks arising from Suspected False Opening by the Supplier

According to the Circular on the Policy of Value-added Tax and Consumption Tax on Exported Goods and Services and the Announcement of the State Administration of Taxation on the Relevant Issues of the Measures for the Administration of Value-added Tax and Consumption Tax on Exported Goods and Services, the competent tax authority shall not apply for export tax refund temporarily for the export business if the competent tax authority finds that in the export business of the export enterprise or other units, the supplier enterprise of exported goods has the existence of falsely issued VAT invoice, etc., and it needs to verify the authenticity of the supply and tax payment of such export business. If the competent tax authority finds that in the export business of the export enterprise or other units, the supplier enterprise of the exported goods has false VAT invoices, etc., which need to verify the authenticity of the supply and the tax payment, the export business will not be processed for export tax refund. If it has been processed, the competent tax authority may suspend the export tax refund for other refundable tax amount that has been examined and approved by the enterprise in accordance with the amount of tax refund involved, and if there is no other refundable tax amount or the amount of refundable tax is smaller than the amount of tax refund involved, the exporting enterprise may provide a guarantee for the difference. Only after the tax authorities have verified and ruled out the corresponding doubts can the tax refund be processed or the guarantee be lifted.

Usually, false VAT invoice is the upstream illegal act of fraudulent export tax refund, and tax cheats often need to obtain the false VAT invoice first to implement export tax cheating, and false VAT invoice is one of the common means of fraudulent export tax refund, so the investigation and handling of false invoicing is an important link to realize the whole chain of combating tax cheating behavior. If the supplier enterprise is suspected of false invoicing, the relevant business of the export enterprise may face the unfavorable consequences of being suspended, withholding tax refund and being required to provide guarantee when it has not yet been investigated.

(II) Tax-related risks arising from "fake self-management, real agency".

The so-called "fake self-management, real agent" refers to the foreign trade enterprises to accept the commission to export in the name of self-management, declared tax rebates, but in essence did not participate in the export transaction activities, only to receive part of the agency service fee business behavior. In the case of tax fraud, the use of "fake self-management, the real agent" mode is actually some of the main body does not meet the conditions of export tax rebates in order to achieve the purpose of tax fraud, the use of foreign trade enterprises to declare the qualification of export tax rebates, so that the relevant personnel can hide behind the foreign trade enterprises to carry out unlawful operations. Under the business mode of "fake self-employment, real agent", foreign trade enterprises can realize profit and other purposes by virtue of their qualification of export tax rebate. In comparison, this business mode is more convenient and efficient than the real self-employment in obtaining economic benefits, and thus a lot of foreign trade companies engage in "fake self-employment, real agent" business mode under the circumstance of low legal awareness and risk prevention consciousness. Therefore, many foreign trade companies have engaged in the business of "fake self-management and real agency" with low awareness of law and risk prevention, which objectively facilitates the tax cheating activities.

According to the principle of export tax rebate collection and management - "who exports, who refunds, who is responsible for". In the "fake self-management, real agent" business, because the entrusted enterprise in its own name to declare exports, foreign exchange, declare tax refunds, should be responsible for export tax refunds. That is, in addition to paying taxes, face fines, stop the right to export tax refunds, but also may face the legal consequences of criminal liability for tax fraud.

(III) filing documents are not complete, false documents triggered by the tax-related risks

According to the Announcement of the State Administration of Taxation on the Issuance of Administrative Measures for Value-added Tax and Consumption Tax on Exported Goods and Services and the Announcement of the State Administration of Taxation on the Relevant Issues of Administrative Measures for Value-added Tax and Consumption Tax on Exported Goods and Services, exporting enterprises shall not declare tax refund and apply the tax exemption policy for the exported goods without filing documents according to the regulations (except for the case that the enterprises do not have the relevant filing documents due to the characteristics of the transaction mode of the exported goods). The exported goods which are not declared for tax refund (except for the case that the enterprise does not have the relevant filing documents due to the characteristics of the transaction mode of the exported goods) shall not be declared for tax refund and shall be subject to the tax exemption policy. If tax refund has been declared, the negative declaration shall be used to offset the original declaration. The competent tax authority shall penalize any failure to bind, store and keep the filing documents in accordance with the provisions of Article 60 of the Law of the People's Republic of China on Tax Collection and Administration. In addition, according to the provisions of the Announcement of the State Administration of Taxation on Issues Concerning Value-added Tax and Consumption Tax on Exported Goods and Services, if the exporting enterprises or other units provide false filing documents, and if the customs, foreign exchange or the competent tax authorities find that the vouchers and filing documents declared by the exporting enterprises for export tax rebate are false documents or their contents are inaccurate, in addition to the policy of not applying the tax rebate, the value-added tax will be levied as if it were the goods being sold domestically. If it is found to be tax evasion, it will be handled in accordance with the corresponding regulations.

The State Administration of Taxation (SAT) has stipulated clear responsibility and obligation clauses for the filing of documents. Enterprises that do not provide the filing documents according to the regulations or provide false filing documents will face corresponding administrative penalties, and may even be investigated for criminal liability for fraudulent export tax rebates. Enterprises must pay attention to this, in the process of export tax rebate business, we must strictly comply with the relevant provisions of the record documents to prevent tax-related risks.

(IV) Risk of Tax Fraud Caused by "Fake Exports"

According to the Announcement of the State Administration of Taxation on the Issuance of Administrative Measures for Value-added Tax and Consumption Tax on Exported Goods and Services and the Circular of the State Administration of Taxation on the Issuance of Administrative Measures for Exported Goods Tax Refunds (Exemptions) (for Trial Implementation), if an export enterprise or other units fraudulently obtains the state export tax refunds by means of false declaration of export or other deceptive means, the competent tax authorities shall recover the tax refunds obtained by the competent tax authorities and impose a fine of not less than one and not more than five times of the tax amount; if a crime is constituted, criminal liability shall be imposed. tax refund, and impose a fine of not less than double and not more than five times of the tax refund; if a crime is constituted, criminal responsibility shall be investigated according to law.

According to the provisions of Article 204 of the Criminal Law, fraudulently obtaining national export tax rebate by false declaration of export or other deceptive means, if the amount reaches a larger standard, constitutes the crime of fraudulently obtaining export tax rebate. At the same time, according to the Interpretation of the Supreme People's Court on Several Issues Concerning the Specific Application of Law in the Trial of Criminal Cases of Fraudulently Obtaining Export Tax Refunds, "False Declaration of Exports" stipulated in Article 204 of the Criminal Law refers to the act of forging or signing a false contract of sale and purchase for the purpose of fictionalizing the fact of export of taxed goods.

From this, it can be seen that the foreign trade enterprises through the signing of false transaction contracts, the use of fraudulent financial flows and other means of deception, constituting a false declaration of export, to bear the recovery of tax refunds, fines, and other administrative responsibilities, the amount of which is larger, constituting the crime of fraudulent export tax refunds, the taxpayer should also be held criminally liable for this. Fraudulent export tax rebates is a relatively serious tax-related legal risks faced by the foreign trade industry, and its tax fraud by the traditional "fake tickets, fake orders, fake goods, no capital flow" to "real tickets, real orders, real goods, fictitious capital flow" change. Counterfeiting or signing of false sales contracts, obtaining export declaration of goods through illegal means, export collection and cancellation of bills of lading and false opening, illegal purchase of VAT invoices and other means to create a false appearance to cover up the fact of tax fraud. However, no matter how confusing the way of cheating export tax rebate is, it is difficult to cover up and change the essence of tax fraud, once the enterprise is recognized by the judicial authorities as tax fraud, it will not only cause great negative impact on the development of the enterprise's operation, but also make the relevant personnel bear administrative responsibility or even criminal responsibility.

III. foreign trade enterprises can use the defense strategy

(I) only the supplier is suspected of false opening, should not be "one-size-fits-all" restriction of the right of the exporting party's tax rebate

According to the aforementioned provisions, if the exporting party is suspected of false opening due to the supplier is suspended, withholding tax rebates or required to provide a guarantee, need to be verified by the tax authorities to rule out the doubt, can only be handled in accordance with the law or to lift the tax rebate guarantee, but this process may be very long. In the author's opinion, if the exporting party can prove that the export business is real and the enterprise has no fault of its own, the right of tax refund should not be strictly restricted all the time.

From the legislative purpose, when the supplier is suspected of false opening, it is necessary to suspend or withhold the tax refund to the exporter or require it to provide guarantee, in order to safeguard the national tax interests, and to prevent the occurrence of the situation that the tax loss cannot be recovered after the supplier is found to be false opening. However, China's Tax Law places equal importance on safeguarding national tax interests and protecting taxpayers' rights and interests.

Therefore, in the stage of investigating the suspicion of false invoicing, every effort should be made to realize the protection of national tax collection and the protection of the legitimate rights and interests of taxpayers in a balanced manner. If the exporting party can prove that the business is real and there is no fault on its part, it means that the trade of the exporting enterprise belongs to normal operation, and even if the supplier is eventually found to have made false invoices, the exporting party only obtains the false invoices in good faith, and ultimately only needs to bear the responsibility of transferring out the input items. If at this stage, regardless of whether the supplier can be ruled out false opening doubt, the right of the exporting party to tax rebate restrictions or even disguised denial, in essence, making the bona fide exporting party to bear the unfavorable risks should not be borne, that is, the exporting party enterprise in this period to bear the tax can not be refunded, or the funds due to the provision of guarantees for a long period of time occupied or even lead to the enterprise capital flow breakage of the unfavorable risks, and if the final can be confirmed that the exporting party business is real and there is no fault in the relevant transaction with the supplier, which is unfair to the exporter.

(II) The business model of "fake self-management and real agency" is indeed illegal but does not necessarily constitute the crime of tax fraud.

The provisions of the tax law on "fake self-management and real agency" are mainly found in the "Circular of the State Administration of Taxation of the Ministry of Commerce on Further Regulating the Order of Foreign Trade and Export Operation and Effectively Strengthening the Management of Tax Refund for Exported Goods" and the "Circular of the Ministry of Finance and the State Administration of Taxation on the Policies of Value-added Tax and Consumption Tax on the Export of Goods and Services", which constitute "fake self-management and real agency", and should be dealt with as follows. According to the provisions of the two documents, it constitutes "fake self-management and real agency" and shall be dealt with as follows:

1、Once discovered, the refunded tax of the business shall be recovered, and the unrefunded tax shall no longer be processed.

2、Fraudulent export tax rebates, the tax authorities to recover the fraudulent tax refunds, and impose fraudulent tax refunds more than double the amount of five times the fine.

3, suspected of constituting a crime, transferred to the judicial organs to investigate criminal responsibility.

According to the above provisions, it can be seen that, for the "fake self-employment, real agent" illegal behavior, the direct way to recover the tax refund, for the tax refund is no longer processed, and whether the behavior constitutes tax fraud, should refer to the "Criminal Law" Article 204, the "Supreme People's Court on the trial of criminal cases of fraudulent export tax refunds on the specific application of the law The Interpretation of the Supreme People's Court on the Specific Application of Law in Trial of Criminal Cases of Fraudulent Export Tax Refunds", the above two documents clearly pointed out that the crime of fraudulent export tax refunds should be based on the perpetrator objectively committing the act of fraudulently obtaining the export tax refunds of the state, and subjectively having the intention of fraudulently obtaining the tax refunds as the constitutive element, so whether the "fake self-management, real agent" business mode constitutes tax fraud should be combined with the subjective and objective judgment of the foreign trade company. Therefore, whether the business mode of "fake self-management and real agency" constitutes tax fraud should be judged by combining the subjective and objective elements of foreign trade companies. In short, whether the foreign trade company engaging in "fake self-management, real agent" business constitutes criminal liability for tax fraud needs to be judged separately and cannot be generalized.

(III) Failure to file registration does not necessarily prove that the enterprise has false transactions

Due to the complexity of the export tax rebate transactions, a variety of modes, in the actual export business, some export enterprises did not sign a written contract of purchase and sale, but signed a verbal contract, electronic contract, how to document this situation for the record? For export enterprises to file documents are electronic data or paperless, you can take one of the following two ways to file:

First, for export enterprises did not sign a written contract of purchase and sale, and entered into a paperless contract, where in line with the provisions of the "Contract Law", the export enterprise will print the electronic contract, oral contract by the export enterprise operator to record in writing the contents of the oral contract and sign a statement that the contents of the record and the fact that the record is consistent with the official seal of the enterprise for the record.

Second, in addition to the oral contract, for export enterprises to enter into electronic purchase and sales contracts, the relevant state administrative departments to take the paperless management of the documents as well as the enterprise's own electronic documents, etc., the exporting enterprise may submit a written application and approval by the competent tax authorities, you can use the electronic documents for the record management, i.e., electronic data for the record of the relevant documents. Export enterprises should ensure the authenticity of the electronic documents for the record, regularly back up the relevant electronic data, in the tax authorities in accordance with the provisions of the record documents, should be required by the tax authorities to truthfully provide electronic data or electronic data will be printed and stamped with the official seal of the enterprise paper documents.

In addition, in practice, there are enterprises can not get part of the filing documents. Such as export enterprises and foreigners to sign a framework agreement for year-round supply, usually exported according to the orders of foreigners, and there is no separate contract, in this case, the author suggests that the enterprise should promptly report to the tax authorities to deal with and retain the appropriate evidence, in the tax authorities in the daily checks and tax audits, should seize the opportunity to fully communicate, the use of the right to state, the right of defense, the right to a hearing to put forward their own claims, in the tax authorities After the tax authorities to make decisions or administrative penalties, the export enterprises are not satisfied with the full use of administrative reconsideration, administrative litigation and other remedies to safeguard their legitimate rights and interests.

(IV) The existence of real goods and export is the substantive element of the defense of tax fraud crime.

Tax authorities in the export tax rebate management, will focus on the authenticity of the goods to verify and check, recognized the existence of real goods transactions, real exports of enterprises, the tax authorities will be timely for the tax rebate. The tax authorities can not deny the fact that the goods have been truly exported when there is no sufficient and effective evidence to prove that the enterprise has falsely exported and has committed tax violations and crimes in export tax refund. Accordingly, when the foreign trade enterprises face the tax authorities audit or through administrative reconsideration, litigation in the defense of the fundamental is that the goods have a real transaction and export, no false opening and other tax violations, the enterprise should collect the relevant information, actively and fully to the tax authorities or the judicial organs to prove the authenticity of its transactions, such as through the inspection report, export confirmation letter, purchase and sales contracts, payment vouchers, export contracts, logistics documents, customs declaration, Manifest, receipt of foreign exchange certificates and other transaction information to be confirmed.

In this case, the Procuratorate to "i-tracking network" can not reflect the goods, consignee units, shipping units and other relevant information for the reason that the foreign trade company there is a real transaction, the author believes that it is inappropriate, "i-tracking network" is a website focusing on the provision of information tracking of water transport container Door to door logistics information tracking website, only need a bill of lading number or booking number, you can query to the export of goods from the entry and exit of the gate, transported to send, customs release, loading and unloading of ships, shipping companies from the port of arrival, sea transit, to the port of destination, pick up the goods and other full process of the box cargo information, because of which can provide a "convenient, trustworthy" box cargo information by our country. Because it can provide "convenient and reliable" cargo information, it has been adopted by more than 100 container terminals and 200 shipping companies in China, which fully proves the reliability of "iTracker" and the authenticity of the cargo information it provides. In conclusion, enterprises should properly save the documents and related documents to prove the existence of real goods and export transactions.

IV. foreign trade enterprises should so strengthen the risk response

For foreign trade enterprises, to prevent tax-related risks, we must first do business compliance, to ensure that the goods, funds, bills and so on in line with the relevant requirements, and at the same time in accordance with relevant legal provisions, timely filing and registration. At the same time, enterprises can establish risk internal control mechanism to ensure that the export business is real and legal, procedural compliance, and then prevent the occurrence of tax-related risks.

In the event of tax fraud disputes, foreign trade enterprises should actively seek ways to remedy their rights. According to the relevant laws, the tax authorities have the right to communicate with the parties on the treatment plan before making the conclusion of the tax audit, and require the parties to make statements and pleadings. Therefore, when the enterprise is in the inspection stage before the conclusion of tax audit is issued, the enterprise should actively coordinate with the relevant departments and seize every opportunity for statement and defense. If the tax authorities intend to make a decision on penalties to the enterprise, the enterprise should make full use of the right of hearing. At the end of the inspection procedure, after the tax authorities have made a decision on treatment or penalty or after the tax authorities have made a decision on non-refund, enterprises are advised to make full use of the remedies of administrative reconsideration and administrative litigation.

When it comes to the crime of tax fraud, as the judicial authorities investigate and handle tax fraud cases, they often start from the aspects of goods flow, capital flow and single bill flow, focusing on the verification through the input and output invoices, i.e., in the aspect of input invoices, tracing the upstream supplier enterprises to see if there is any low-priced or false opening, and in the aspect of output invoices, judging whether there is any suspicion of overstating export and cheating the export tax rebate through the unit price and the total price. And then according to the invoicing situation, whether there is a return of funds to investigate the whole transaction chain in the acquisition, production, sales process is normal. Therefore, foreign trade enterprises should be properly preserved to prove the existence of their own real goods transactions, real export materials. At the same time, foreign trade enterprises should actively seek professional help to maximize the help of enterprises to recover losses and maintain the rights and interests of export tax rebates.