On July 28, the State Council Information Office held a series of themed press conferences on the launch of the 15th Five-Year Plan.

Wang Daoshu, Deputy Director of the State Taxation Administration, released a set of data at the meeting:

In the first half of this year, authorities nationwide investigated and dealt with various tax-related violations in accordance with the law, recovering 180.6 billion yuan in tax losses, a year-on-year increase of 20.8%.The

Among them, enterprises that fraudulently obtained or improperly claimed tax incentives were investigated and penalizedMore than 3,200 households, Revenue from Audits and Adjustments12 billion yuan; Investigate and punish companies suspected of issuing fraudulent invoices and tax evasion32,400 households, to recoup losses from export tax rebates4.6 billion yuan; Investigate and punish tax-related intermediaries that violate regulationsMore than 500 householdsThe

180.6 billion, up 20.81% year-over-year TP3T—When viewed together, these two figures send a very clear message:The intensity of tax audits continues to increase.

If you’re also involved in export business and are unsure whether your tax refund filings are compliant, or if you’re concerned about past records being audited, feel free to add us on WeChat and send us the basic details—Qicaiying will help you make a preliminary assessment.

Add me on WeChat at qcygscszk or call 18676749275

01 export tax rebate(math.) genusIt is becoming a “hotspot” for inspections”

Among this set of data, the item that deserves the most attention from cross-border e-commerce sellers is this one:

32,400 companies suspected of issuing fraudulent invoices and tax fraud were investigated and penalized, recovering 4.6 billion yuan in lost export tax rebates.The

Why Are Export Tax Rebates Subject to Intensive Audits?

First, export tax rebates involve “real money.”

Export tax rebates are direct refunds by the government of input taxes already paid by enterprises and are classified as “fiscal expenditures.” Falsely reporting exports or forging documents to fraudulently obtain tax rebates directly results in losses to the national treasury. Therefore, export tax rebates have always been a key focus of tax audits.

Second, the export tax rebate process involves a long chain of steps and many participants. 

From procurement, production, customs clearance, and logistics to foreign exchange receipt, the entire process involves multiple stages and parties. If a problem arises at any stage—such as procurement based on a fictitious transaction, customs declarations that do not match the actual goods, or foreign exchange receipts that do not match the export amount—the system may flag it as an anomaly.

Third, a joint enforcement mechanism involving eight government agencies is now in place. 

Eight agencies—the State Taxation Administration, the Ministry of Public Security, the Supreme People’s Court, the Supreme People’s Procuratorate, the People’s Bank of China, the General Administration of Customs, the State Administration for Market Regulation, and the State Administration of Foreign Exchange—have established a routine joint enforcement mechanism. Over the past two years, nationwide inspections have targeted more than130,000 households, found to have issued fraudulent VAT invoices to external parties7.38 million copies; Investigate companies involved in export tax fraud4,850 households, to recoup losses from export tax rebates24.6 billion yuan. Data sharing, joint analysis, and the transition from administrative law enforcement to criminal justice—this chain is now firmly in place.

02 Why Do Cross-Border E-Commerce Sellers Face Higher Risks?

If you're a cross-border e-commerce seller, the following three issues may be putting you at risk:

Question 1: Export Invoicing

Many small and medium-sized sellers use freight forwarders to “export under their name”—that is, they use the customs declaration details provided by the freight forwarder, without handling customs clearance or receiving foreign exchange themselves. In the past, this might have gone “unnoticed,” but now—Customs declaration data, logistics data, platform sales data, and foreign exchange receipts—these four data systems are automatically cross-checked. Your goods have been shipped, the payment has been received, but your name isn’t on the customs declaration—how will the system flag this?

Issue 2: Non-compliant export tax rebate filings

Some sellers file for export tax refunds through third-party customs brokers, but there are inconsistencies between the purchase invoices, customs declarations, and shipping documents. For example, the item description on the purchase invoice may not match that on the customs declaration, or the number of packages listed on the shipping documents may not match that on the customs declaration.The Golden Tax Phase IV system integrates data from tax authorities, customs, and banks, and any discrepancies are automatically flagged by the system.

Question 3: Hidden Risks Left by Historical “Order Bundling”

In the past, to meet the minimum threshold for tax refunds, some sellers would combine different orders when filing customs declarations or use unrelated invoices to match customs declarations. In the era of “data-driven taxation,” these practices,All of them will be identified as anomalies by the system.. Furthermore, the Golden Tax Phase IV system can retrieveHistorical data from the past 5 to 10 yearsConduct a thorough scan—there’s no such thing as “it’ll be safe in a few years.”

03 real case::Proactive Self-Inspection vs. Reactive Inspection

Since 2026, the wave of tax backpayments by publicly traded companies has fully demonstrated that“The Cost Difference Between ”Proactive Self-Inspection“ and ”Reactive Inspection”The

The vast majority of publicly traded companies explicitly state in their announcements that “Based on our internal review,” “no administrative penalties are involved.” . In other words, they proactively conducted a self-audit and made the back payments after receiving a tax risk alert,Exempt from a fineThe

But what if you’re caught during an audit and found to have evaded or defrauded taxes?

According to the *Tax Collection and Administration Law*, once a taxpayer is found to have evaded, resisted, or defrauded taxes, the tax authorities will recover the taxes owed.There is no 3- or 5-year statute of limitations; back taxes may be collected indefinitely.. In addition to paying back taxes and late payment penalties, you may also faceFines ranging from 0.5 to 5 times the amountThe

The costs associated with conducting a proactive self-inspection are in a completely different league from those incurred when violations are discovered during an audit.

04 What should I do now?

First, review your export tax rebate filing records.

Retrieve your export tax rebate filing records from the past 2–3 years and review the following: purchase invoices, customs declarations, shipping documents, and foreign exchange receipts—Is there a logical contradiction among these four? Do the item names, quantities, and amounts match up?

Second, assess the risks associated with “invoice-based exports.”

If your goods were exported via a freight forwarder using the “invoice-based export” method, please confirm immediately: Who is listed as the consignee on the customs declaration? Who received the foreign exchange proceeds?Platform sales data, logistics data, customs declaration data, and foreign exchange receipts—do these four sets of data align with one another?

Third, the sooner historical issues are addressed, the lower the cost.

The audit data totaling 180.6 billion clearly illustrates the trend:Tax audits will only become stricter, not more lenient. If you proactively conduct a self-inspection and make the back payments, it is highly likely that you will “not face administrative penalties”; however, if you passively wait for the system to flag a problem, the consequences will be entirely different.

05 What can Qi Cai Ying do for you?

To address the tax compliance needs of cross-border e-commerce sellers and export companies, Qicaiying offers:

• Risk Assessment for Export Tax Rebates
  Comprehensively review purchase invoices, customs declarations, logistics documents, and foreign exchange receipts to identify potential risk areas
• Review of Historical Records and Compliance Remedial Actions
  After identifying an issue, develop a compliant and cost-effective solution
• Guidance on Compliance with Export Tax Rebate Filing Requirements
  Ensure that the submitted materials are complete and logically consistent to reduce the risk of an audit.
• Tax Risk Management Support
  If you have received a tax notice, assist in preparing explanatory materials and cooperate with communications.
• Cross-Border Tax Structuring
  Optimize the overall tax burden through compliance measures such as Hong Kong companies and offshore exemptions

Who is this for?

• Cross-border e-commerce sellers engaged in export business—Using a freight forwarder to “pay for exports” and submitting non-compliant tax refund claims
• Export companies that have received tax risk alerts—I don't know how to handle this
• Companies interested in learning about export tax rebate compliance requirements—Mitigate Risks Early

If you’re also involved in export business and are unsure whether your tax refund filings are compliant, or if you’re concerned about past records being audited, feel free to add us on WeChat and send us the basic details—Qicaiying will help you make a preliminary assessment.: Add WeChat ID qcygscszk or call 18676749275

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.

statement denying or limiting responsibility

The content of this article is compiled based on data from official press releases by the State Taxation Administration and publicly available information. It is intended to provide general information on finance and taxation and to highlight compliance risks; it does not constitute any tax, legal, or financial advice. The specific application of policies is subject to the determination of the competent tax authorities. If readers encounter specific tax issues, they should consult a qualified tax professional or the competent tax authority. Qicaiying assumes no legal liability for any losses arising from reliance on the content of this article.