June 22, the Shenzhen Bureau of Commerce, in collaboration with Amazon Global Selling, hosted a public livestream. This livestream sent a very clear message—9810 is an ”innovative direction” for cross-border e-commerce exports”, Shenzhen is moving forward with the development of the 9810 tax refund support system, with plans toComplete development by the end of this yearThe

However, the completion of system development does not mean it’s ready for immediate use. After development, there are still interdepartmental integration testing, internal testing, and rollout—a process that takes at leastHalf a year. Before that,For most small and medium-sized sellers, the 9810 tax refund process remains a path that is ”feasible in theory but fraught with obstacles in practice.”

So here’s the question: Since the 9810 tax refund process isn’t an option for now, does that mean we have to keep paying for exports and wait to be audited?

It's not.

9810: In addition to the tax refund, there's one more thingDuty-Free Lane—No tax refund, but it’s compliant; no need to wait for the system to go live—you can get started right now.

In today’s article, we’ll walk you through the entire practical process for 9810 export tax-exemption filing in Shenzhen and Guangzhou—from preparing the necessary qualifications to submitting the filing application—all in one go. Feel free to scan the QR code to add Qicaiying’s online customer service (WeChat ID: jxhqcy890).👉Based on your specific situation, we’ll assign a professional consultant to address your questions and provide one-on-one, end-to-end compliance solutions.

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01 Let’s get this straight: What exactly is the difference between the 9810 tax exemption and the tax refund?

For many people, the moment they hear ”9810,” the first thing that comes to mind is “tax refund.” In fact, there are two paths for 9810:

Option 1: 9810 Export Tax Rebate

Prerequisite:The supplier must be a general taxpayer, and the purchasing party must obtain13% Special VAT Invoice

Advantage:After exporting, you can apply for a refund of input tax, which helps accelerate cash flow.

Pain Points:Processing refunds first and then verifying them makes the verification process for multiple batches and SKUs extremely complex;The review period for the first tax refund is 8–12 months.; Local tax bureaus do not apply the standards uniformly, and many localities are reluctant to approve applications

Route 2: Duty-Free at Exit 9810

Prerequisite:Both small-scale taxpayers and general taxpayers can do this; the procurement side receivesby unanimous votecan immediately (do sth)

Advantage:No need to pay export VAT, and no need to perform complex tax refund calculations or follow-up write-offs

Disadvantage:By forgoing the tax refund, the input tax on purchases cannot be recovered

Simply put: A tax refund means ”you pay for the ticket up front, and the tax is refunded to you when you leave the country”; tax-free means ”you are not charged VAT at the time of export, but any VAT paid previously is not refunded.”

with regards toAnnual sales of less than 50 millionFor small and medium-sized sellers with few stores who cannot obtain stable special invoices from their suppliers, tax-exemption is the most practical option at this stage.

To put it simply, a tax refund is the ideal solution, while tax-free shopping is the practical solution for now. Which one you choose depends on your current receipts, transaction history, and patience.

02 Shenzhen/Guangzhou 9810 Tax-Exempt Filing: A 5-Step Process

Step 1: Determine whether your business is eligible for the 9810 tax exemption

First, ask yourself three questions:

① What is the relationship between your store model and the export entity?

If you arePremium Mode——A ”retail company” refers to an export company with a relatively limited range of SKUs and a stable inventory replenishment schedule, making it easy to qualify for the 9810 tax-free program.

If you areStock Distribution Model, Multiple Stores——There is currently some uncertainty regarding the consolidation of 9810 declarations through a single export company. After the data required by Document No. 15 was submitted, some sellers who had been consolidating 9810 declarations across multiple stores for two years reported that discrepancies arose between the data submitted by the platform and the data declared by the company,Tax refunds have been suspended. Although tax exemptions do not involve tax refund write-offs, it is still necessary to confirm the feasibility of centralized filing with the competent tax authority.

② What types of invoices can you obtain from the purchasing side?

If you consistently receive 131 TP3T special invoices → you may want to consider applying for a tax refund (but be prepared for an audit)

Can only get general admission tickets →Shop Duty-Free

Can't even get a regular ticket →Under the current 9810 policy framework, tax exemption isn’t an option. We need to resolve the issue of procurement invoices first, and then discuss the export customs clearance process.

Remember this golden rule:Whether you’re opting for tax-free purchases or tax refunds, you must have an invoice before making a purchase. General invoices are eligible for tax-free treatment but not for tax refunds on exports, while special invoices are eligible for tax refunds on exports. Without an invoice, there’s no point in even discussing it.

③ Can you accept the uncertainty surrounding 9810?

The 9810 system is still under development. There are variations in how local policies are implemented, communicating with the tax authorities involves a time cost, and reconciling data during write-offs is complex. Choosing the 9810 system means actively embracing these uncertainties.

If you pass all three questions, proceed to the next step.

If you also have a company in Shenzhen or Guangzhou and need advice on the 9810 export tax-exemption filing 👉 Scan the QR code to add our online customer service representative (WeChat ID:jxhqcy890), arranging professional managers to answer queries and provideFull Process Compliance ProgramOne-to-one service ↓↓↓

Step 2: Preparing Qualifications Before Export

This step is a major hurdle,If even one is missing, you can't go on the 9810::

1. Additions to the Scope of Business on the Business License

Add ”Import and Export of Goods and Technology”

2. Customs Registration

Registration of Import/Export Shippers and Consignees, Registration of Cross-Border E-Commerce Enterprises, and Application for Electronic Port IC Cards

3. Tax Filing

General Taxpayer Status (required for tax refunds; also available for tax-exempt small-scale taxpayers), Application for Export Tax Refund (Exemption) Filing

4. Foreign Exchange Filing

Registration in the Foreign Exchange Enterprise Directory; Opening of Foreign Currency Accounts (or Activation of International Currency Fund Functions)

5. DXPID Application (Choose One of the Following)

Self-Reporting Model:Apply for a DXPID on your own and use the public service platform to push encrypted messages to the customs system. This is suitable for sellers with high order volumes and IT capabilities.

Agent-Based Filing Model:Instead of applying for a DXPID on your own, entrust a freight forwarder or customs service provider with 9810 certification to handle the data submission using their DXPID. Small and medium-sized sellers generally opt for this approach to get up and running quickly and avoid the costs of building their own system.

Step 3: File for Export Tax Rebate (or Exemption) Registration

This is the most crucial step.

Registration Requirements:

① Customs registration as an importer or exporter has been completed

② Has obtained certification of eligibility for export tax refunds (or tax exemptions) (for general taxpayers) or filed for tax-exempt status (for small-scale taxpayers)

③ Engages in actual export operations (exports that have been cleared through customs)

Registration Process (Applicable to Both Shenzhen and Guangzhou):

1. Log in to the Electronic Tax Bureau → [Tax Services] → [Export Tax Rebate Management] → [Export Tax Rebate (Exemption) Filing]

2. Fill out the “Export Tax Refund (Exemption) Filing Form” and select“Tax-Free”way (of life)

3. Upload the following documents: a copy of the business license, customs registration receipt, Electronic Port IC card information, and bank account opening permit

4. After submitting, wait for the tax authority to review it; generally,5-10 working days

Special Notice for Shenzhen:There are differences in enforcement practices across Shenzhen’s various districts. In cross-border e-commerce hubs such as Longgang and Bao’an, tax authorities are relatively familiar with 9810 operations, resulting in lower communication costs. However, some newly established tax administration offices may lack practical experience with 9810 tax-exemption filings, requiring step-by-step communication. It is recommended to communicate with your assigned tax officer in advance to confirm the required documentation and the review timeline for the filing.

Special Notice for Guangzhou:The cross-border e-commerce public service platforms in the Huangpu and Nansha districts of Guangzhou are relatively well-established, and they have considerable practical experience with 9810 registration. We recommend prioritizing these two districts for registration.

Step 4: First Export Declaration + Duty-Exempt Declaration

Once the filing is approved, you can proceed with customs clearance for the first shipment under HS code 9810 for export:

Customs Clearance Process:

After the goods have left the country, Customs issues an export declaration form (which serves as the legal proof of departure).

It is recommended to confirm the customs declaration pricing with the relevant tax authority: Should it be based on GMV or actual receipts? Currently, there is no uniform standard across different regions.

→ Reported based on GMV: The figures match the data submitted by the platform, but there is a discrepancy in actual cash receipts that needs to be written off.

→ Report based on actual receipts: This reflects cash flow more accurately, but differs from the platform’s GMV data.

Tax-Exempt Declaration Process:

Small taxpayers:Fill in the ”Tax-Exempt Export Sales” section of the “Value-Added Tax Return (for Small-Scale Taxpayers)”

General taxpayers:Fill in the relevant fields under ”Sales of Exported Goods and Services Eligible for Exemption, Offset, and Refund” on the “VAT Exemption, Offset, and Refund Return” (select the tax exemption method).

Key: Maintain the chain of evidence

Although the 9810 tax-exempt status does not involve tax refund accounting, a complete chain of evidence must be retained for tax audits:

① Export Declaration Form (issued by Customs)

② Logistics documents (first-leg bill of lading, overseas warehouse receipt)

③ Platform sales data (order records, sales reports)

④ Proof of foreign exchange receipt (withdrawal records from third-party payment platforms, corporate bank account statements)

⑤ Purchase invoice (corresponding to the input invoice for the exported goods; a standard invoice is acceptable)

Step 5: Ongoing Compliance Maintenance

Just because the filing is complete doesn’t mean you’re in the clear—there are a few steps you must continue to take:

① Monthly Filing

Submit VAT exemption returns on time each month to ensure that the reported data matches the customs declaration data and platform data.

② Foreign Exchange Receipts Management

The 9810 tax-exemption program does not require opening a foreign currency account; funds can be withdrawn directly to a corporate account through third-party payment platforms such as Wanlihui and Lianlian.

Ensure that the foreign exchange receipts match the customs declaration forms.

Funds from multiple stores can either be transferred to Hong Kong first and then consolidated into the mainland corporate account, or they can be received directly into the mainland corporate account without going through Hong Kong.

③ Retention of Sales Data

There is no need to process a pre-tax refund reconciliation, but you must retain sales data for tax audits. We recommend maintaining a simple ledger: customs declaration batch → receipt into overseas warehouse → sales shipment → foreign exchange receipt records

④ Annual Corporate Income Tax Settlement and Finalization

Tax-Exempt Income from Exports Must Be Included in Corporate Income Tax Returns

Overseas expenses (platform commissions, advertising fees, and warehousing fees) may be included in costs based on pro forma invoices and payment records.

⚠️ Attention:The pre-tax deduction limit for advertising expenses is15%, Commission Limit5%——In Line with the Reality of the Cross-Border Industry40%-55%There is a significant difference in the cost structure, so this needs to be discussed and planned in advance.

Ultimately, the 9810 duty-free process isn’t just a matter of ”completing the filing and calling it a day”; rather, it involves a comprehensive set of procedures—including customs clearance, declaration, foreign exchange receipt, documentation, and record-keeping—all of which are essential.

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03 Common Pitfalls to Avoid in the Practical Implementation of the Shenzhen/Guangzhou 9810 Duty-Free Program

Pitfall 1: Filed for recordation but did not clear customs

Some sellers think they’re ”in compliance” just because they’ve completed tax-exemption registration, but in reality, they still rely on freight forwarders to handle the export process. Registration is one thing; customs clearance is another.If you do not file customs declarations for exports under your own company’s name, your tax-exemption status is effectively meaningless.

The mandatory prerequisite for tax-exempt exports is that the goods must actually leave the country and be accompanied by an export declaration form issued by customs.

Pitfall 2: The customs declaration price differs significantly from the platform data

The customs declaration listed $100, but Amazon’s GMV shows $150, and the platform reported $150 to the tax authorities. The discrepancy is too large, triggering an automatic system alert. We recommend confirming the reporting criteria with the relevant tax authority before filing the customs declaration,Declare customs based on the estimated receipt price (amount received)This is currently the most reliable approach.

Pitfall 3: Unclear Foreign Exchange Receipt Channels

Platform Wallet → Third-Party Payment Collection → Personal Card—this process will no longer be valid in 2026. The compliant process should be:Platform Wallet → Third-Party Payments → Business Bank Account. Every step is documented, and the flow of funds tells a story.

Pitfall 4: The purchasing side doesn’t have an invoice but still insists on using the 9810 tax-exempt procedure

Under the current policy framework for 9810, without input invoices, it is not possible to file for tax exemption.If you are unable to produce purchase invoices during a tax authority audit, the authenticity of your exports may be called into question. At best, your tax-exemption status will be revoked; at worst, your exports will be treated as domestic sales and you will be required to pay back taxes.

No tickets → Sort out the ticket issue first → Then discuss the export customs clearance process. There are no shortcuts.

Pitfall 5: Filing a consolidated tax return for multiple stores without notifying the tax authorities

Whether multiple stores can consolidate their shipments through a single export company under HS code 9810 isn’t up to you—it’s up to the tax authorities. Following the issuance of Document No. 15, some sellers have had their tax refunds suspended because their consolidated declaration data did not match the information reported by the e-commerce platforms. We recommend communicating with your local tax authority in advance to confirm the feasibility of consolidated reporting and obtaining verbal or written approval from the tax authority before proceeding.

Pitfall 6: Assuming that just because a company is tax-exempt, it doesn’t need to worry about corporate income tax

Although VAT on exports is exempt, corporate income tax must still be paid. Retail companies are liable for corporate income tax and must file their own tax returns based on the audited accounting method.Many sellers assume that if they qualify for tax exemption, they don’t have to pay anything—they’re exempt from VAT, but not from income tax.

The root of these pitfalls isn’t a lack of understanding of the policies, but rather mistaking ”filing” for ”compliance” and ”tax exemption” for ”not having to pay taxes.”

04 Shenzhen/Guangzhou 9810 Tax-Free vs. Savi Model: Which One Should You Choose?

Sellers often ask: “I’m currently using the SAIWEI model (0110). Should I switch to the 9810 tax-free option?”

Here’s a framework to help you make a decision:

If any of the following apply to you, we recommend using the 9810 duty-free procedure:

① Premium Model: Few stores (1–3), with annual sales of over 5 million per store

② The store or company itself is the exporter and does not need to consolidate the data.

③ The purchasing party can obtain a standard invoice

④ We want to establish a customs clearance model that best aligns with the nature of Amazon’s overseas fulfillment center inventory management business.

⑤ Willing to invest time in communicating with the tax authorities

If you fall into any of the following categories, we recommend continuing with the Savi model (0110):

① List products across multiple stores (10 or more stores)

② Exports must be consolidated and declared through a single customs declaration.

③ Some purchase transactions have invoices, while others do not

④ I don’t want to go through the hassle; I want a well-established process that’s recognized nationwide.

⑤ Need for a tax refund (the tax refund process under 0110 is more established)

Core Principle: The key is to align with the substance of the business. 9810 is not necessarily ”the most compliant,” nor is 0110 necessarily ”non-compliant.”

The Shenzhen Bureau of Commerce also made it clear during the live stream: Regulators recognize that Amazon store clusters are a necessity for cross-border sellers looking to expand into overseas markets, and they will adjust their regulatory approach based on the business model. It’s not the case that 9810 is the only option.

For cross-border sellers in Shenzhen and Guangzhou,The regulatory environment in 2026 no longer allows for a ”wait-and-see” approach.. With platform data reporting, freight forwarders required to report the true shipper, and end-to-end transparency across the entire supply chain—these three measures now fully in place—the room for survival of “buy-and-ship” export operations is rapidly shrinking.

To qualify for the 9810 tax exemption, you must do at least one thing:You have customs declarations for your exports, invoices for your purchases, foreign exchange receipts processed through your official account, and supporting documentation for your tax filings.

This isn't what you'd call perfect compliance, but it is“Compliance That Can Be Accounted For”The

Ultimately, there is no single “best” model—only the one that best suits your business at its current stage. A good model is one that aligns with the substance of your business and can withstand scrutiny from the tax authorities.

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If you’re considering applying for the 9810 tax-exempt filing or aren’t sure whether your business qualifies, feel free to reach out to us. We’re available atShenzhen, Guangzhou, Foshan, DongguanEach has a support team that can help you:

① Assess whether the business model is suitable for the 9810 tax exemption

② Assist with the complete set of procedures for export tax refund (or exemption) registration

③ Coordinate with the relevant tax authority to confirm the reporting guidelines

④ Establish a comprehensive compliance process covering everything from customs clearance to filing declarations

⑤ After upgrading to a general taxpayer, evaluate whether to switch tax refund schemes

⑥ Free Assessment for 9810 Tax Exemption Filing