On July 8, the Xiamen tax authorities publicly disclosed three cases of export tax rebate fraud. The three companies were collectively ordered to pay back taxes and fines totaling more than 20 million yuan; in the case involving Anlaite (Xiamen) Import and Export Co., Ltd., the fines and confiscated funds amounted toAs high as 9.429 million yuan.

Behind these figures lies a change that deserves even greater attention: the methods used in tax audits have undergone a complete transformation. Instead of examining ledgers or waiting for tips, tax authorities now proactively cross-reference three information chains—logistics, funds, and invoices—using tax big data. Wherever there’s a discrepancy, that’s where they find a breakthrough.

This article breaks down the real details of three cases, explains how big data exposes ”mismatches between invoices and goods,” and identifies three high-risk areas for cross-border e-commerce sellers regarding export tax rebates.

I. Three Cases: A Quick Overview at a Glance

When viewed together, these three figures show that the fine amounts to approximately2 times. If you defraud 1 million, you’ll be fined 2 million—this isn’t just a matter of ”paying back the money”; it’s a heavy penalty based on a multiplier.

II. The Full Story of the Anlaite Case: How Big Data Was Exposed

Anlaite is the case with the most complete details disclosed among the three. Looking back at the entire process, it is clear that tax audits have developed a highly systematic tracking process.

Step 1: On-site verification triggers an alert.

When tax authorities conducted an on-site inspection, they discovered that Anlite had long since vacated its office space and that the company’s representative could not be contacted—a classic sign of ”absconding.”

Step 2: Trace the logistics based on the tax refund data. 

The inspectors didn’t stop there. They retrieved Anlight’s export tax refund records from the tax system, took that data to the relevant docks, and traced back to identify the corresponding logistics companies and truck information.

Step 3: The discrepancy between the ticket and the goods reveals a flaw. 

A comparison revealed that the place of origin of the goods declared by Anlaite differed from the actual place of shipment.Significant Discrepancy. The goods were produced in Location A, exported from Location B, but the declaration information listed Location C—the documents and the goods are completely disconnected.

Step 4: Abnormalities in the transaction history. 

After reviewing the bank transaction records, two typical patterns of irregularities emerged: first, ”large-value invoices, small-value payments”—invoices totaling hundreds of thousands, but the actual payment for goods was only a fraction of that amount; second, funds that ”come in and go out immediately”—funds were transferred out quickly after being credited to the account, without the retention period typical of genuine transactions.

Step 5: Verification of upstream relationships is complete. 

An even more critical step: The tax authority in the location of the upstream invoicing company issues a letter confirming that the special VAT invoice issued to Anlite isFalsely Issuing or Forging. At this stage, all three aspects—the flow of goods, the flow of funds, and the flow of documents—have been fully secured.

Ultimately, in October 2025, the Xiamen tax authorities imposed penalties on Anlaite for fraudulently claiming export tax rebates: the total amount of back taxes and fines collected was9.429 million yuan.

Keep in mind this time lag: the period from when an anomaly is detected to the final penalty may span more than a year. During this process, the tax authorities have already compiled a complete chain of evidence in their system. Once big data audits are further rolled out in 2026, the investigation and enforcement cycle for similar cases will only become shorter, and the accuracy will only increase.

III. The ”High-Risk Tax Refund” Trio: Each Is Being Targeted with Precision

Anlaite is not an isolated case. The common characteristics of these three cases areIssuing False Special VAT Invoices...but the specific approach points to three ”gray-area practices” in the cross-border e-commerce industry that have persisted for many years.

① Export sales without invoices; purchases without invoices. 

The core logic behind this type of operation is as follows: Without input invoices or export qualifications, the perpetrators export goods using customs declaration forms under someone else’s name—either borrowed or purchased—and then use falsely issued invoices to support their tax refund claims. The problem is that the three flows—goods, funds, and invoices—do not align. In the past, these schemes went undetected due to data silos; now, however, the tax system has integrated logistics data, customs declaration data, and banking data, so anomalies resulting from a ”mismatch of the three flows” automatically trigger alerts.

② ”Separate Invoicing” — The invoice and the goods are shipped separately. 

The crux of the Anlaite case is the separation of invoices and goods. The goods listed on the invoices were produced at Factory A, while the goods actually exported were shipped from Warehouse B—the two streams never intersected. Faced with big data cross-checks, this ”pieced-together” declaration structure crumbled at the first sign of scrutiny.

③ Rapid inflows and outflows of funds; receipt of payments into personal accounts. 

For companies involved in fictitious trade chains, it is very difficult to make their cash flows appear ”real”—in genuine transactions, payments for goods involve payment terms, final installments, and installment payments; whereas cash flows from fraudulent invoices are often characterized by ”lump-sum payments followed by immediate transfers.” In the eyes of the tax authorities, bank transaction records are essentially an unfurled timeline, and the abnormal patterns of rapid inflows and outflows are immediately apparent.

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IV. By 2026, the regulatory approach to export tax rebates had shifted gears

These three cases are not isolated incidents, but rather a snapshot of a systemic tightening of regulatory oversight.

1. The audit-based taxation system has been fully implemented. 

Starting in 2026, cross-border e-commerce companies will uniformly be subject to tax assessment based on audited accounts, and the previously prevalent policy of tax assessment based on fixed rates will be phased out. This means that every item of revenue must be supported by corresponding cost documentation, and every invoice must withstand cross-verification between upstream and downstream parties.

2. Big data connectivity has been largely achieved. 

The tax system has integrated data from five key areas: customs declarations, logistics, bank transactions, factory information, and invoices. In the past, audits relied on on-site inspections of ledgers and tips from the public—a process that was inefficient and had limited coverage. Now, the system proactively screens for anomalies, and human intervention occurs only after suspicious activity is identified, transforming ”blind audits” into ”targeted audits.”

3. Penalties have been increased. 

The two-fold fines imposed in these three cases speak for themselves. According to the *Tax Collection and Administration Law*, those who fraudulently obtain export tax rebates shall be fined an amount equal to one to five times the amount of tax fraudulently obtained; if such acts constitute a crime, criminal liability shall be pursued. A two-fold fine is the starting point, not the upper limit.

V. Three Key Steps for Compliance with Export Tax Rebates

Given the current situation, cross-border e-commerce sellers must ensure their export tax rebate compliance aligns with three fundamental principles:

• The tickets must be genuine. 

Ensure that every purchase is accompanied by a compliant VAT special invoice, and that the seller listed on the invoice matches the actual supplier. If an invoice is determined by an upstream tax authority to be a fraudulent invoice, the downstream enterprise’s eligibility for a tax refund will be retroactively revoked, even if it was ”unaware” of the fraud.

• The goods must be correct. 

The goods information on the customs declaration form (description, quantity, value, and country of origin) must match the goods actually exported. Sellers with multiple stores or suppliers should pay particular attention to ensuring that the goods match correctly when filing consolidated declarations.

• The money has to add up. 

The path for collecting export proceeds must be clear and traceable. If payments are received through third-party payment platforms, offshore accounts in Hong Kong, or even personal accounts, you will be required to provide a complete explanation of the funds’ flow during a tax refund audit—if the chain of funds is broken at any point, your eligibility for a tax refund may be denied.

Export tax rebates are a legitimate source of revenue, not a financial management tool to be used with the mindset of ”saving wherever possible.” The biggest lesson from the three Xiamen cases is not ”how much was fined,” but ”how the violations were uncovered”—in the age of big data, discrepancies between invoices and goods, abnormal fund flows, and fraudulent invoicing by upstream suppliers: every single lead is precisely captured by the system. By 2026, regulatory scrutiny will no longer be a matter of “if” you’ll be investigated, but “when” you’ll be caught.

If your export tax refund declaration involves any of the following situations—such as unclear sources of purchase invoices, discrepancies between customs declaration data and actual shipments, or a multi-layered transfer chain for foreign exchange receipts—we recommend proactively conducting a full-chain compliance review before the system issues a warning.

If you have any needs, please feel free to contact Qicaiying, and we will tailor a solution just for you:Cell phone: 18676749275 ｜ WeChat: qcygscszk

Enterprise Finance Group

Founded in 2015 and headquartered in Shenzhen, Qicaiying Group is a leading provider of corporate services and tax compliance solutions in China.

The Group is deeply committed to providing services across the entire corporate lifecycle. Its core business areas include: business registration, bookkeeping services, tax compliance, overseas company registration (Hong Kong, the U.S., Singapore, Mexico, etc.), cross-border structuring, outbound direct investment (ODI) filing, overseas tax planning, bank account opening assistance, and identity planning.

Over the past decade, Qicaiying has served more than 10,000 corporate clients and has accumulated solid practical experience in key areas such as corporate structuring in Hong Kong and overseas, cross-border tax and financial compliance, and corporate accounting management. The Group boasts a team of seasoned financial and tax advisors who closely monitor changes in domestic and international tax systems and regulatory trends, providing clients with one-stop solutions ranging from structural planning to implementation.