Have you ever found yourself in this situation—

When buying goods on 1688, after asking about the price, I always follow up with, “Boss, how many percentage points extra for an invoice?”

Most suppliers gave the same response: “No invoice without a markup; a 10-point markup for a special-purpose invoice.”

You did the math: annual purchases amount to tens of millions, and if you requested receipts for all of them, the extra cost would be several million. “What you save is profit.” So you decided not to ask for receipts.

Under the previous fixed-rate tax system, whether or not you had an invoice didn’t affect your tax payment, so you didn’t think this was a problem.

But right at the start of 2026, your finances told you something that might have kept you up all night:

“The fixed-rate tax assessment has been abolished; starting this year, tax assessments must be based on audited accounts. If you don’t have purchase invoices, not a single cent of your purchase costs can be deducted—it will all be counted as profit.”

When you open the supplier chat window on 1688, you realize that every time you said, “Can you give me a discount if I don’t need an invoice?” it now seems like you were setting yourself up for trouble.

If you currently source your products primarily through channels such as 1688, have been unable to obtain cost invoices for an extended period, and have annual sales exceeding 5 million yuan, you can start by scanning the QR code to add us.WeChat: qcygscszk or call 18676749275...Conduct a “shortfall analysis for purchases without invoices” to figure out exactly how close you are to a “financial disaster.”

01 Why was everything fine before, but now there's a problem?

Previous Environment: Cross-border e-commerce is subject to a fixed-rate tax assessment, with profits determined as a fixed percentage of revenue (2%–4%).... You do not need to provide cost invoices. Whether or not you have purchase invoices has no impact on your tax liability.

Change No. 1: The comprehensive audit-based taxation system has officially taken effect.

Starting in 2026, the fixed-rate taxation method will no longer apply to cross-border e-commerce; instead, it must be aligned with domestic trade tax administration rules and subject to examination-based taxation. Every item of revenue, cost, and expense must be supported by valid documentation.. Costs for which no invoice is available must be adjusted upward for tax purposes during the corporate income tax annual settlement.

Change No. 2: The threshold for general taxpayers is being strictly enforced.

New regulations for 2026 specify that businesses with annual sales exceeding 5 million will be automatically reclassified as general taxpayers for the current period.. Once a company becomes a general taxpayer, the tax rate jumps from 1% to 13%. If it cannot obtain input invoices, it must pay the full amount of VAT at the 13% rate—with sales of over 5 million, the VAT alone comes to 650,000.The

Change No. 3: Tax audits are now focusing on purchases made without invoices.

The State Taxation Administration is stepping up targeted audits of corporate income tax for cross-border e-commerce companies, focusing on verifying purchases without invoices, the falsification of costs, and the issuance of fraudulent invoices for tax credits.. In the first half of 2026, 108 A-share listed companies issued announcements regarding back taxes, totaling 9.641 billion yuan.The

Have an impact: What used to be a cost-saving strategy of “skipping invoices” is now turning into a trap where “skipping invoices leads to higher taxes.” For a business with a gross profit margin of 30%, failing to obtain a purchase invoice could result in the tax burden directly eroding all profits.

02 What Problems Does Procurement Without Invoices Actually Cause?

During the era of audit-based taxation, procurement without invoices raised at least three issues:

First, the costs are not tax-deductible, resulting in a sharp increase in corporate income tax.

Without an invoice, the tax authorities won’t recognize your costs. Even though you clearly spent money on purchases, these costs cannot be deducted on your books and are instead counted entirely as profit.

Let's do the math (annual sales of 10 million, gross profit margin of 30%):

• If invoices are available: 7 million in deductible costs, 3 million in taxable profit, and 750,000 in corporate income tax.
• In the absence of invoices: Zero deductible expenses, taxable income of 10 million, corporate income tax of 2.5 million

For the same business, pay an extra 1.75 million. This 1.75 million isn’t “extra profit”; it’s your procurement cost—it’s as if you’re paying taxes on behalf of the supplier.

Second, the VAT credit chain has been broken.

Without input invoices, you cannot claim input tax credits. After registering as a general taxpayer, if you are unable to obtain input invoices, you must pay the full amount of VAT under code 13%.The

Take an annual sales figure of 5 million as an example: Without an invoice, the VAT = 5 million × 13.1% = 650,000. With a special VAT invoice, input VAT can be offset, so the actual amount payable may be only a few ten thousand or even zero.

650,000 vs. a few ten thousand—that’s the difference between getting a receipt and not.

Third, the historical costs associated with long-term procurement without invoices cannot be remedied.

Many sellers think, “I’ll just start asking for invoices from now on—that should be enough”—but the procurement costs from previous years can no longer be traced. Suppliers simply cannot issue retroactive invoices for purchases made three years ago.

When a tax audit takes place, none of the costs from previous years can be claimed as deductions. Not only will you have to pay back taxes, but you’ll also have to pay late payment penalties and fines. You spent that money back then, but simply because you didn’t ask for receipts, it was all wasted.

03 Four Compliance Solutions for Procurement Without Invoices

The good news is that there are compliant ways to make purchases without invoices. Sellers of different sizes and operating under different models have different approaches to follow.. You can choose from the following four options based on your individual circumstancesThe

Option 1: Export Tax Rebate Model (with Special VAT Invoices)

Application: Enterprises eligible to receive special VAT invoices for their purchasesThe

operating method: When making purchases, require suppliers to issue special invoices that match the goods declared for customs clearance; declare the goods for export using codes 0110, 9710, or 9810; and collect the customs declaration forms, foreign exchange receipt vouchers, and special invoices to file for a tax refund.The

dominance: Profits can be boosted through tax refunds. For example, an 8-point cost of issuing invoices corresponds to a 13-point tax refund, resulting in a net profit of 5 points.

for whom: Sellers with relatively centralized procurement and some bargaining power with suppliers. This is the optimal solution for medium-to-large sellers with a well-established bill-of-exchange process, offering the highest level of compliance.

Option 2: Tax-Exempt Model Without Invoices in the Comprehensive Pilot Zone (No Special VAT Invoices)

Application: Companies registered in the Cross-Border E-Commerce Comprehensive Pilot Zone that engage in 9610 (retail exports)The

Policy basis: According to Document No. 103 [2018] of the Ministry of Finance and the State Administration of Taxation, e-commerce export enterprises in comprehensive pilot zones that export goods for which they have not obtained valid purchase documents may, if eligible, benefit from a trial policy granting exemption from value-added tax and consumption tax.. Specific requirements include: registering in the pilot zone and submitting export information via the online integrated service platform, as well as completing export declaration procedures through the customs office where the pilot zone is locatedThe

Progress on Implementation: In February 2026, Shenzhen launched a “tax-free shopping without a receipt” registration module, enabling a fully digital process.. Wenzhou has also launched the 9610 duty-free service for purchases without an invoiceThe

take note of: Tax-exempt transactions without invoices ≠ no accounting records. Tax-exempt transactions without invoices address VAT issues related to exports, but corporate income tax still requires supporting documentation for costs.The

for whom: Sellers registered in the Comprehensive Pilot Zone who engage in B2C retail exports and are unable to obtain special invoicesThe

Option 3: 1039 Market Procurement Model (Individual Business Owners Without Invoices)

Application: Small shipments, mixed cargo, no invoice. In pilot cities, customs clearance is handled through sole proprietorships, with the declared value per shipment ≤ $150,000.The

operating method: Register as a sole proprietor in a pilot area, complete market procurement filing, use Form 1039 for export customs clearance, and be exempt from tax on purchases made without invoices; corporate income tax is assessed based on a fixed rate.The

dominance: No invoice required for tax-free purchases; low overall tax burden. For 1 million in export revenue, the tax payable is approximately 5,000 to 15,000 yuan.. By 2026, 1039 had become an officially recognized, compliant export channel for ticket-free exports that could be used on a long-term and stable basis.

take note of: It is extremely difficult to establish a presence in Shenzhen due to geographical and merchandise value restrictions; businesses must operate on-site in pilot areas.The

for whom: Sellers who source their inventory from multiple, small-batch suppliers in specialized marketsThe

Option 4: Hong Kong Company Procurement + Domestic Service Company Model (Compliant Without Invoices)

Application: Medium- to large-sized enterprises (with annual exports of 20 million or more) that make purchases without invoices and need to repatriate foreign exchange in compliance with regulationsThe

operating method: The Hong Kong company purchases goods directly from mainland suppliers who do not issue invoices and pays for the goods; the Hong Kong company applies for an “offshore exemption” (if the supplier or customer is not a Hong Kong entity and the transaction does not take place in Hong Kong, the company is exempt from the 16.51% profits tax).; Establish a service company in mainland China to provide cross-border services—such as supply chain management—to Hong Kong companies, and legally repatriate foreign exchange to mainland China based on the “Tax Exemption Filing for Cross-Border Taxable Transactions.”The

dominance: Dual Tax Optimization (Hong Kong Tax Exemption + Domestic Service Tax Exemption), Compliant Capital RepatriationThe

for whom: Sellers who are already using a Hong Kong company to receive payments, have significant annual sales, and are interested in establishing a multi-entity structureThe

04 There are three things you need to do right now

Step 1: Conduct an analysis of procurement gaps caused by a lack of purchase orders.

List the procurement records from the past year: which suppliers can issue invoices, which cannot, how many percentage points must be added if an invoice is issued, and what the total shortfall is. First, get a clear picture of the “current situation.”The

Step 2: Choose a compliance path based on your specific circumstances.

• Major suppliers capable of issuing special invoices → Use the export tax rebate model
• Registered in the Comprehensive Pilot Zone and engaged in retail exports → Utilizing the tax-free, invoice-free model
• Sourced from multiple suppliers, small batches → Consider the 1039 market procurement model
• Annual exports exceeding 20 million, with an existing Hong Kong company → Considering a Hong Kong-based procurement structure

Step 3: Follow up with suppliers to ensure they issue invoices and establish a chain of evidence.

Discuss invoicing arrangements with suppliers—including the percentage mark-up, how to issue invoices, and when to issue them—and ensure these details are specified in the contract.The

The good news is that on April 7, 2026, the State Taxation Administration issued preliminary guidelines on tax-related issues for cross-border e-commerce enterprises, clarifying that foreign invoices, receipts, and detailed statements of platform fees may be used as documents supporting tax-deductible expenses.. As long as the transaction is genuine and the chain of evidence is complete—contracts, payment records, shipping documents, and warehouse receipt records—none of these can be missing.——You can then claim a pre-tax deductionThe

If you’ve been unable to obtain cost invoices for an extended period, your annual sales have exceeded 5 million yuan, and you’re unsure which path to take, you can scan the QR codeWeChat: qcygscszk or call 18676749275, with the note “purchase without an invoice.” We’ll do two things for you:

• First, calculate exactly how large your gap in purchases without invoices is and how much your tax burden will increase;
• Second, based on your procurement model, supplier structure, and sales volume, we will recommend the compliance path that best suits your needs.

What can Qi Cai Ying do for you?

Qicaiying specializes in financial and tax compliance for cross-border e-commerce supply chains and offers the following services to clients making purchases without invoices:

① Analysis of the Current Situation of Procurement Without Invoices
We’ll analyze your procurement sources, suppliers“ willingness to issue invoices, cost structure, and tax gap to help you calculate exactly how much extra tax you’ve paid due to ”invoice shortages.”

② Four compliance pathways that provide a precise match
Based on your business model—purchasing concentration, number of SKUs, place of registration, and sales volume—we recommend the optimal approach: export tax rebates, tax-exempt sales without invoices, Form 1039, or a Hong Kong structure.The

③ Plan to Encourage Suppliers to Issue Invoices
We’ll help you negotiate invoicing terms with suppliers and evaluate the total costs of “invoicing with the tax added,” “switching suppliers,” and “pursuing alternative routes.”

④ Remedies for Historical Cost Accounting
Organize past procurement records and payment documents, and strive to maximize deductible expenses in accordance with the latest guidelines from the State Taxation Administration.The

If you're worried about procurement without invoices and aren't sure where to start, scan the QR code to add usWeChat: qcygscszk or call 18676749275, with the note “purchase without an invoice”—we’ll help you sort it out.