Compliance in cross-border e-commerce has enteredThird GenerationThat's it.
In the first generation, businesses made money through export transactions by capitalizing on information asymmetries and tax differentials, but this approach has essentially become unviable since the launch of the Golden Tax Phase IV system;
Option 2: Register a Hong Kong company and operate independently. This allows goods to be exported and money to be repatriated, but since the supply chain and invoicing issues remain unresolved, it can only be considered a ”stopgap measure”;
The third generation—that’s what we’re going to talk about today Saiwei 2.0 Model—A comprehensive, closed-loop compliance system that integrates everything from architecture, goods flow, and cash flow to tax processing.
If you’re struggling with these issues—being hesitant to process payments, not knowing how to use your Hong Kong company, being unable to claim tax refunds, or having profits stuck overseas that you can’t repatriate—this article will provide you with a comprehensive solution.
If you want to transition to compliance but aren’t sure how to proceed, feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat: jxhqcy890 / Mobile: 16625410105)👉Based on your specific situation, we’ll assign a professional consultant to address your questions and provide one-on-one service for a comprehensive compliance solution throughout the entire process.

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Let me start by sharing a real-life example
Client Background: A seller in the 3C category in Shenzhen, with annual sales of approximately150 million, a dual-channel approach using Amazon and an independent website. In the past, I’ve always used the “purchase-based export” method: once the goods were shipped, the funds were transferred back to my personal card through a third-party payment processing platform. I’ve never claimed an export tax refund, nor have I ever complied with domestic tax regulations.
The situation when they found us: Following the implementation of the Golden Tax Phase IV initiative, banks have significantly tightened their oversight of large-scale fund transfers involving personal bank accounts, and the boss’s personal account has been frozen in the past.Twice; at the same time, suppliers upstream in the supply chain cannot issue invoices, making it impossible to claim tax refunds; overseas profits have been sitting in Payoneer and Wanlihui accounts for a long time, and we’re afraid to transfer them back to China.
This is not an isolated case. Among the cross-border e-commerce companies we have served in Shenzhen, Guangzhou, Foshan, and Dongguan,Sellers with annual sales exceeding 50 million face similar compliance issues at the 80% level and above—their goods, funds, and invoices don’t align. While they may appear to be making money, they’re actually operating without proper safeguards.
The SAIWEI 2.0 model is specifically designed to address this ”three-no” issue.
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Saiwei 2.0 isn't just about ”registering a company”; it's a comprehensive systemCoordination Among Four Key StakeholdersArchitectural design. Each entity performs its specific role, separating the four processes—store opening, export, procurement, and service—to ensure that every step is legal and compliant.
① Overseas Companies (Hong Kong/Singapore)
As the registered entity for the store, it interfaces directly with the platform (Amazon, independent websites, etc.). Overseas companies receive payments from the platform, which serve as the ”first point of profit.” Hong Kong was chosen because of its simple tax system, free flow of foreign exchange, and tax arrangements with the mainland.
② Domestic Export Companies
Be responsible for customs clearance for exports under the ”General Trade (0110)” category. This is the cornerstone of compliance for the entire framework—the goods are legally cleared through customs in the name of the exporting company, creating a record with customs authorities and providing the basis for tax refunds. Without this step, everything that follows is built on sand.
(iii) Domestic Supply Chain Companies
Responsible for purchasing from factories and obtaining special VAT invoices. These serve as the ”ticket” to a tax refund—you can only claim a refund with an invoice; without one, you must opt for tax-exemption or a tax assessment. The supply chain company sells the goods to the export company, thereby establishing a complete domestic procurement chain.
④ Domestic Service Companies
Responsible for operational, graphic design, customer service, and other service functions, and collects service fees from overseas companies. Service fees are settled in RMB, allowing for the legal repatriation of a portion of profits while providing the team with domestic social security coverage and acting as the payroll entity.
Four entities, four functions, all interlinked. The core logic is:Goods are shipped via an export company for customs clearance (legal export) → Invoices are processed through a supply chain company for procurement (compliant invoicing) → Funds are received by an overseas company (foreign exchange compliance) → Profits are repatriated through service fees and trade markups (funds compliance)The
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The tax treatment for Savi 2.0 essentially boils down to two key accounts; once you understand these two, the tax logic behind the entire model becomes clear.
Entry 1: Value-Added Tax—Export Exemption + Input Tax Credit
Goods declared for export by an export company,VAT Exemption Policies(No VAT is payable at the export stage.) At the same time, the supply chain company may apply for an export tax refund for the input tax corresponding to the special VAT invoices it obtains during procurement.
Simply put: No taxes are paid when goods are exported, and the taxes paid at the time of purchase can be refunded. This is a policy benefit designed to encourage exports, and it represents the greatest tax advantage of the SAIWEI 2.0 model.
Item 2: Corporate Income Tax—Paid Locally
Domestic export companies, supply chain companies, and service companies each operate within the country,On-Site Filing and Payment of Corporate Income Tax. Profits earned by overseas companies are subject to taxation within China once they are repatriated to domestic companies in the form of service fees or trade markups.
This means that all profits are ultimately subject to domestic tax compliance, and there is no gray area where ”profits are parked overseas without being taxed.”
Voters vs. Non-Voters: A Set of Data That Shows the Gap
This is the question sellers ask most often. We use100 millionHere’s a comparative analysis of sales volume:
| comparison term | Ticket available (0110 Refund) | No Ticket (Tax-Exempt/Approved) |
|---|---|---|
| Value-Added Tax on Exports | Exempt from | Value-Added Tax Exemption |
| Input Tax Treatment | Tax-refundable (approx. 13%) | Non-refundable |
| 100 million in tax refunds | About 10 million | 0 |
| Closed-Loop Compliance | Full Closed-Loop System | Unable to close the loop for 100% |
| flow of funds back | Official Channels | A different route must be found |
100 millionIn terms of sales volume, between those with tickets and those without,The tax refund difference is approximately 10 million, and the difference in the overall tax burden could reach 12.5 million.. That is why we have always emphasized: If you can issue an invoice, you must do so; claiming a tax refund based on the invoice is the best way to maximize your benefits.
What if you don’t have a license? Even without a license, you can still operate in the duty-free sector by using a Hong Kong-based company to set up a store as part of a compliance solution—we’ll cover this in detail in a future article.
At the end of the day, if you have receipts, you can claim a tax refund—100 million will get you 10 million back; if you don’t have receipts, you can only buy duty-free, and you won’t get a single penny back. Once you do the math, you’ll know which option to choose..
When comparing several common compliance solutions available on the market, the advantages of Saiwei 2.0 are immediately apparent:
| programmatic | Architecture | tax rebate or refund | flow of funds back | Compliance Level |
|---|---|---|---|---|
| buy orders to sell goods (e.g. for export) | No subject | not have | Gray | ⚠️ Illegal |
| Hong Kong-only Entity | Overseas companies only | not have | Incomplete | Partially Compliant |
| 9,810 per store | Cross-Border E-Commerce Retail | For informational purposes only | Limited | Policies Need to Be Improved |
| Saiwei 2.0 | Coordination Among Four Key Stakeholders | ✓ Returnable | ✓ Complete | ✓ Fully Closed-Loop |
Which Sellers Are Suited for Saiwei 2.0?
Saiwei 2.0 isn’t a one-size-fits-all solution; it’s clearly intended for a specific audience. If you meet any of the following criteria, we recommend getting started as soon as possible:
① Annual Sales20 millionThat's all
② Currently processing the export payment
③ Has a Hong Kong company but no corporate structure
④ Profits are tied up overseas
⑤ The personal card has been frozen in the past
⑥ Want to claim export tax rebates but have no way to do so
⑦ Preparing for financing or a merger or acquisition
⑧ The supply chain can issue invoices
Special Note:If your supply chain cannot issue an invoice, While the tax refund process for Savi 2.0 isn't feasible, we have other compliant solutions that can address this issue; a one-on-one assessment is required to determine the specifics.
Let’s be honest: Savi 2.0 isn’t the only solution, but it’s currently the only one that can fully integrate architecture, logistics, cash flow, and tax management. For sellers who can issue invoices, there’s no reason not to use it.
📌 Is Your Architecture Ready for Scrutiny?
Saiwei 2.0 is too complex to cover fully in a single article; every seller’s situation is different—Can the supply chain issue invoices? How much capital is held overseas? Who is currently the legal entity for the store? Is the team based in China or overseas?
The answers to these questions will determine how you structure your compliance program.
Compliance transition is better sooner rather than later, the earlier the layout, the lower the cost, the more stable the development.
📌 If your business is currently at one of the following stages:
[Start-up period] Annual revenue < 20 million: Worried about the impact of zero filing, private collection, and Golden Tax Phase IV?
[Development Period] Annual revenue 20 million-100 million: troubled by export tax rebates, multiple private accounts, financial chaos?
[Maturity] Annual revenue > 100 million: thinking about equity design, inventory optimization, IPO readiness?
We have the corresponding solutions and practical experience.
The SAIWEI 2.0 model can’t be fully explained in a single article, as every seller’s situation is different. If you’re struggling with compliance-related challenges—such as being too afraid to conduct export transactions under your own name, not knowing how to use your Hong Kong company, being unable to claim tax refunds, or having profits stuck overseas that can’t be repatriated—
👉 Scan the QR code to contact Qicaiying’s online customer service (WeChat: jxhqcy890 / Mobile: 16625410105), arrange for a professional manager to answer questions and provideFull Process Compliance ProgramOne-to-one service ↓↓↓
