Many cross-border e-commerce sellers are puzzled: The policy clearly states that 9810 shipments are eligible for tax refunds, so why haven’t I been able to get a refund after trying several times?

I submitted the documents over and over again, only to have them rejected each time. When I asked the case officer, they simply said, ”The materials are incomplete.” But no one told me what exactly was missing or how to fix it.

This article explains that when a 9810 tax refund cannot be processed, in the vast majority of cases it is not due to operational errors, but rather because your underlying business architecture simply cannot support the tax refund requirements.

I. Basic Requirements for the 9810 Tax Refund

Let’s clarify the prerequisites first. To qualify for a tax refund under the 9810 program (cross-border e-commerce exports to overseas warehouses), the following conditions must all be met:

✔️ Do you have import and export rights?

✔️ You are a general taxpayer and have completed the export tax refund registration process.

✔️ The goods were cleared for export under the 9810 procedure and shipped to the overseas warehouse

✔️ The goods have been sold from the overseas warehouse (it’s not enough for them to simply arrive at the warehouse; actual sales data is required)

✔️ A complete chain of documentation: customs declaration, special VAT invoice, foreign exchange receipt, and logistics documents—all four must match.

✔️ The foreign exchange receipt amount, customs declaration amount, and invoice amount all match

If even one of these six conditions is missing, we won’t be able to withdraw. It’s not a matter of ”we might not be able to withdraw,” but rather ”we definitely won’t be able to withdraw.”

II. The Real Reason You Can’t Get It Done

Reason 1: An inherent break in the document chain

This is the most common issue. The 9810 regulation requires that customs declarations, VAT invoices, foreign exchange receipts, and shipping documents all match. However, for sellers who list products across multiple stores:

✘ You may source your purchases from dozens of suppliers, many of whom cannot issue special invoices.

✘ Your shipment may be handled by a freight forwarder using consolidated containers, so the customs declaration may not match the actual shipment.

✘ Your payments are settled centrally through a third-party payment tool and cannot be matched to individual customs declarations.

The tax authorities have grounds to reject every single discrepancy. It’s not that you’re doing something wrong; it’s that your business model inherently conflicts with the documentation requirements of Form 9810.

Reason 2: The cost of operating a single store is prohibitively high

If you have 30 stores and 300 SKUs, according to policy requirements, each store must file customs declarations, maintain separate accounting records, and process tax refunds independently. This means: 30 sets of customs declaration documents, 30 rounds of document verification, and 30 tax refund processes.

Not to mention the operational costs—the probability of errors alone is absurdly high. If a single store’s documentation doesn’t match up, the entire tax refund process can come to a standstill. Many sellers give up after trying just once—not because they don’t want a refund, but because it’s simply too much to handle.

Reason 3: You didn’t set up the framework first and just jumped straight into filing for a tax refund

Tax refunds are not the first step; they are the final step. The correct sequence is: First, establish a compliant structure (unify the export entity, streamline the procurement chain, and align customs declaration methods) so that the structure itself meets the conditions for a tax refund—and then proceed with the tax refund process.

But for many people, it’s the other way around: they first try to claim a tax refund using the existing model, get rejected, and then scramble to patch the gaps—but for every one they fix, two more pop up. Because the underlying architecture doesn’t support it, no matter how you patch things at the operational level, there will always be gaps.

III. The Right Approach: Focus on the Framework First, and Tax Refunds Will Follow Naturally

If your current business model prevents you from lowering the 9810 rate on your own, don’t keep struggling with it. Go back to the architectural level and address these three core issues:

① Centralized Export Entity: Instead of each store filing customs declarations individually, a single supply chain company handles all exports centrally—reducing customs clearance costs, minimizing documentation errors, and streamlining the tax refund process.

② Establish a complete closed-loop process for procurement, export, and sales: Factory → Procurement by the supply chain company (invoicing) → Export by the supply chain company (tax refund) → Resale by a Hong Kong company or overseas entity → Sales at retail stores. Each stage is accompanied by corresponding documentation and transaction records.

③ A chain of evidence integrating the four flows: contract flow, fund flow, logistics flow, and invoice flow—all retained and archived in accordance with standards recognized by the tax authorities.

Once the framework is in place, tax refunds are a natural outcome—because your business model already meets all the prerequisites for tax refunds.

Has your 9810 tax refund application been repeatedly rejected? Scan the QR code to add a Qicaiying consultant, who will help you determine whether the issue stems from operational errors or structural problems and provide actionable recommendations for correction.

Cell phone: 18676749275 ｜ WeChat: qcygscszk

IV. Why Choose Qicaiying for Compliance Structuring?

It’s not hard to find a compliance solution; the challenge lies in finding a team that can actually implement it—one that understands your business model, is familiar with the tax authorities’ requirements, knows how to coordinate between Hong Kong and mainland China structures, and has the resources to help you secure the necessary qualifications and complete the procedures at every stage.

A Professional Team—Customization Is More Than Just a Slogan

Qicaiying’s professional team of nearly 400 people consists of certified public accountants, tax agents, cross-border tax and finance consultants, and Hong Kong-licensed secretaries. The firm holds three TCSP-licensed secretary licenses and operates its own Hong Kong accounting firm. On-site due diligence is standard practice—we first assess the scale of your store network, fulfillment model, and supply chain structure before developing a customized solution. No two clients receive the exact same framework, because no two clients’ businesses are alike.

Digital Systems: Ensuring Architecture Implementation Remains True to the Original Design

We’ve invested tens of millions to develop our own digital management system, standardizing all key execution points of the compliance framework and making progress visible. From processing import and export licenses to filing for tax refunds and exemptions, and from establishing Hong Kong companies to standardizing capital flows, the completion status of every step can be tracked in real time. We don’t just give you a PDF proposal—we guide you step by step to make it a reality.

Ecological Resources: Solving the Problem of ”Who to Turn to Next After the Solution Is Complete”

Qicaiying connects with over 500,000 entrepreneurs and domestic and international association platforms, including the Shenzhen Cross-Border E-Commerce Association. By establishing a compliance structure through Qicaiying, you don’t just receive a set of solutions—you also gain simultaneous access to a fast-track for opening Hong Kong bank accounts (through multiple channels such as HSBC, Overseas-Chinese Banking Corporation, Dah Sing, and CBI), cross-border payment resources, overseas warehouse integration, and supporting audit and tax services, thereby resolving the question of ”who to turn to next” once your compliance structure is in place.

The quality of a compliance framework depends on whether it is actually implemented effectively. Choosing the right team ensures that the plan doesn’t remain merely on paper.

Has your 9810 tax refund application been repeatedly rejected? Scan the QR code to add a Qicaiying consultant, who will help you determine whether the issue stems from operational errors or structural problems and provide actionable recommendations for correction.

Cell phone: 18676749275 ｜ WeChat: qcygscszk