01 A system warning, how many sellers sleepless nights

In 2026, Golden Tax Phase IV entered the full implementation phase.

Cross-border e-commerce sellers are accustomed to the ”approved levy” formally withdrawn from the stage of history, the platform sales data, bank capital flow, customs records and invoices, has been the system of real-time cross-referencing.

This is not a surprise inspection, but a long-running automated monitoring mechanism.

May 31 is the final deadline for filing 2025 Historical Income Amendable Returns on an active basis. After this point, the cost difference between active and passive will be calculated in multiples.

02 What exactly is Golden Tax IV looking at?

Many sellers' understanding of Golden Tax Phase IV still stays at the level of "getting on a tax system". But in fact, what Golden Tax IV does is to connect the following four data chains and complete the cross-comparison in real time in the background:

• order flow--Platform back-office sales flow (Amazon, Sizzle, Temu, etc. have access to the data reporting)
• financial flows-- Records of receipts in public bank accounts and counterparty accounts
• logistics flow--Declared amounts and commodity names in customs declarations
• invoice flow-Name, quantity and amount of VAT input invoices

Once any of the following 'Four Streams of Disruption' occurs, the system will automatically warn and even directly push for an audit:

It's not a matter of probability of 'bad luck being drawn' - it's an inevitable result of the system running out automatically.

03 Three things that will revolutionize the game in 2026

Piece One: Full switchover of checking and collecting

In the past, many cross-border e-commerce sellers enjoy the approved levy - 2%-4% of sales directly after the tax, the operation is simple, low tax burden.From 2026, the State Administration of Taxation (SAT) is clear: cross-border e-commerce is fully converted to a check-and-balance levy.

This means that for every income and every cost you incur, there must be a complete accounting counterpart. No entry tickets? No compliance vouchers? Then that cost can't be deducted pre-tax, which directly pushes up the corporate income tax.

Piece 2: Rigid landing of the VAT Law

The new VAT Law was formally implemented in 2025 and entered the enforcement phase in 2026. The export tax exemption and refund policies applicable to cross-border e-commerce are no longer 'verbal defaults' - the customs declaration methods (9610/9710/9810), invoice management, and declaration time nodes are all included in the rigid compliance requirements.

Third piece: clarity of the platform's data reporting obligations

Platforms such as Amazon and Sizzle have initiated or will soon initiate the process of reporting seller sales data to Chinese tax authorities."The money is offshore and not visible to the Internal Revenue Service" - a logic that is no longer valid.

04 May 31: The last 'surrender' window

This is one of the most important times of the day, so please read it carefully.

According to the caliber of the current policy: the historical stock of income in 2025 and before can still be declared on a retroactive basis at the approved levy rate.

Simply put:The tax burden of proactive retroactive reporting is relatively manageable; waiting for the system to find out and then retroactively reporting will cost more than 10 times as much as the former, or even face a fine of 0.5 to 5 times.

Window period for supplemental filings:May 31, 2026 (the closing date for amendments to the 2025 Annual Report).After May 31, this window officially closes. At that time, once the system triggers an audit with an early warning, the tax will be paid directly according to the checking of accounts, and there will be no room for negotiation.

There are still 12 days left - if you're not sure if you need to file a retroactive return, or if you're not sure what to do, now is the time to contact us for a simple self-check assessment:

Cell phone: 18676749275 ｜ WeChat: qcygscszk

Give us a brief description of your company and we'll help you determine your risk level and give you targeted advice.

05 Hong Kong companies, are they still available?

In the past few years, "registering a Hong Kong company + offshore account collection" is almost a standard action for cross-border e-commerce sellers. After the landing of Golden Tax IV, many people are asking the same question:Can Hong Kong companies still do it?

The answer is: if it is used legally, it can be used; if it is used as a shell, it is dangerous. The problem is not the Hong Kong company itself, but whether it has "business substance".

The tax authorities determine whether a Hong Kong company has substance and usually assess it in the following dimensions:

Once recognized as an "Insubstantial Shell Company" by the Mainland tax authorities, it will directly trigger aControlled Foreign Corporation (CFC) Clause--- means that the foreign retained profits will be penetrated and paid back at 25% EITC.

06 How to put together a compliance structure? The Right Way to Play Mainland + Hong Kong + Overseas

Compliance does not equal skyrocketing tax burden. A truly compliant structure is one that rationalizes the allocation of functions and reduces the combined tax burden within the regulatory framework.

Mainland companies (operating entities)

• Apply for general taxpayer qualification and enjoy export tax rebate
• Undertake supply chain management, domestic procurement and other functions
• Standardize the management of input invoices to reduce the corporate income tax base

Hong Kong company (trade transit)

• Sign genuine three-way trade contracts and earn compliant spreads
• Take advantage of the offshore income exemption to legally reduce your tax liability
• Prerequisite:Must have substance, including registered address, business traces, bank records

Customs clearance model matching

Different sales scenarios correspond to different customs clearance modes, and mismatch will directly lead to tax risks.

07 Whatever your current situation, assess before you act

If you are currently facing any of the following situations, it is recommended that you complete a special compliance self-study by May 31st:

• Hong Kong company receives money for a long time but has never done any audit or tax declaration.
• The amount of public account receipts is much lower than platform sales
• Mixed customs declarations, 9610/9810/9710 never system planned
• High percentage of non-invoiced purchases, concern about pre-tax deduction risk
• Corporate structure has not been adjusted for many years, not sure of compliance

The sooner this compliance thing is dealt with, the lower the cost. Golden Tax IV is not a surprise inspection, it is a set ofAutomated monitoring mechanisms for long-term operation. The later you act, the less space is left for you.

Now, there are 12 days until the window closes.

Cell phone: 18676749275 ｜ WeChat: qcygscszk

Add WeChat and note "Tax Compliance", we will arrange professional consultants to dock with you at the first time and assist in completing the compliance disposal within the window period.

08 Enterprise Caiying: professional compliance support for cross-border e-commerce sellers

Enterprise Caiying has been deeply engaged in cross-border enterprise services for many years, and the scope of services covers the whole chain of cross-border sellers' fiscal and tax compliance:

There are no bystanders in the matter of compliance. The "four streams in one" monitoring system of Golden Tax Phase IV has already exposed all business behaviors to the sunlight. Proactive compliance is the most effective way to protect yourself.