In the second half of 2026, a regulatory overhaul affecting millions of cross-border e-commerce sellers is rapidly taking effect. The State Taxation Administration, the General Administration of Customs, the Ministry of Commerce, the State Administration of Foreign Exchange, the Ministry of Finance, and the State Administration for Market Regulation—these six major agencies have taken action almost simultaneously, rolling out a comprehensive package of new policies covering audit-based taxation, overseas warehouse registration, and foreign exchange settlement. The most widely circulated saying in the industry is: The era of ”letting the water flow to nurture the fish” in cross-border e-commerce has officially come to an end.

Data speaks volumes. In 2025, China’s total cross-border e-commerce imports and exports exceeded 2.7 trillion yuan—a scale so vast that it can no longer be treated as an ”exception.” As platform transaction volumes, customs declaration data, logistics tracking, and foreign exchange remittances are all digitally recorded, data across tax, customs, foreign exchange, and market regulation agencies is rapidly being integrated—the compliance loopholes that once relied on information asymmetries to allow each agency to ”manage only its own segment” are being closed at a visible pace.

For many sellers, the most immediate impact of this round of new policies is the change in the tax calculation method. Previously, a large number of cross-border e-commerce companies benefited from the simplified tax calculation method of ”fixed-rate taxation,” but in the future, they will, in principle, transition to a system of tax assessment based on actual profits through audit, as the scope for fixed-rate taxation continues to narrow. At the same time, the legalization of overseas documentation has become a mandatory requirement—companies must provide complete documentation for overseas procurement, warehousing, and logistics. In other words, maintaining accurate “accounts” is no longer an optional choice but a survival threshold that determines whether a company can continue to operate.

In light of these policy changes, Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and other locations, as well as annual company audits, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI and FDI filings, and other corporate services; Hong Kong residency applications, renewals, and permanent residency services; Singapore Employment Pass (EP) application services; and cross-border e-commerce mentoring and managed operations—all as part of our one-stop service. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

I. How Exactly Does ”Audit-Based Taxation” Work? Understanding the Direction Through Three Dimensions

To understand this new round of policies, we must first clarify the fundamental difference between ”audit-based taxation” and ”fixed-rate taxation.” Under assessed taxation, tax authorities ”estimate” the tax liability based on parameters such as industry profit margins using a fixed rate, and businesses are not required to provide complete financial records; whereas under examination-based taxation, businesses are required to file accurate returns based on their actual accounting records, ensuring that every component—including revenue, costs, expenses, and profits—matches up.

In the context of cross-border e-commerce, regulatory ”inspections” focus on three key areas:

First, the entire revenue chain is traceable. Platform order data, payment transaction records, customs declaration amounts, and logistics documents will serve as cross-verification evidence for revenue recognition. The past practice of maintaining ”one set of books for the platform and another for tax filings” has become virtually impossible to conceal under the ”data-driven tax administration” approach of the Golden Tax Phase IV initiative.

Second, cost-side documents must be legitimate. Overseas procurement, initial logistics, overseas warehouse storage, and platform commissions—every cost must be supported by genuine and legitimate documentation. If you cannot provide the necessary documentation, these costs cannot be deducted before taxes—which naturally increases your tax base.

Third, Related-Party Transactions and Corporate Structure. Whether prices for transactions involving multiple stores, multiple entities, and related parties both domestically and internationally are fair is also a key focus of audits. In the past, many sellers” ”pricing arrangements” between their Hong Kong and mainland entities were rather arbitrary; now, they must be reevaluated in accordance with the arm’s-length principle.

II. Policies Are Not a ”One-Size-Fits-All” Approach: The Other Side of Tightening Is the Benefits

This round of new policies is not solely about tightening; there are also measures to ease restrictions. The Ministry of Finance has clarified that goods returned from cross-border e-commerce exports will be exempt from import duties, value-added tax, and consumption tax at the import stage, with this policy in effect through the end of 2027; The General Administration of Customs has introduced 25 measures to facilitate cross-border trade, including extending the tax exemption for returns under the 9610 tariff code through the end of 2027, implementing cross-customs district returns nationwide, and transitioning overseas warehouse registration to a paperless process; the Ministry of Commerce has expanded the scope of entities eligible for ”invoice-free tax exemption” through the 178 national cross-border e-commerce comprehensive pilot zones; The State Administration of Foreign Exchange has comprehensively promoted the facilitation of foreign exchange receipts and payments for cross-border e-commerce. Compliant enterprises can now conduct net settlement and benefit from quotas exempt from transaction-by-transaction document review, shortening the payment recovery cycle by 3 to 7 days following large-scale inventory purchases during peak seasons.

The underlying message of this set of policy measures is clear: regulators are using ”compliance facilitation” to reward sellers with transparent accounting, complete documentation, and who pay taxes in accordance with the law, while using ”audit-based taxation combined with data cross-checking” to weed out business entities operating in a legal gray area. Compliant businesses will enjoy faster clearance, lower costs, and easier access to financing; for non-compliant businesses, the risks of back taxes, fines, and even losing their business registration are rising sharply.

III. What Should Sellers Do Now? An Actionable Compliance Roadmap

Given the increasingly clear policy direction, waiting and seeing is the most costly strategy. Here’s a compliance roadmap for all sellers that you can start implementing today:

Step 1: Conduct a ”financial and tax health checkup.” Gather all platform transaction records, payment receipts, purchase documents, and shipping documents from the past two years, and cross-check them item by item against your accounts to identify discrepancies and risk areas. Many people assume they’re ”in the clear,” but a closer look often reveals numerous loopholes—early detection allows for early remediation.

Step 2: Establish a standardized accounting system. Upgrade from ”casual bookkeeping” to formal accounts that comply with tax requirements. Recognize revenue based on both platform orders and actual payments received; aggregate costs according to supporting documents; and allocate expenses on a periodic basis. This step is the foundation for tax assessment based on audited accounts and a prerequisite for subsequently benefiting from various streamlined tax policies.

Step 3: Complete the chain of foreign documentation. For overseas procurement contracts, warehouse expense receipts, logistics tracking records, and platform commission statements, submit any missing documents as soon as possible. For those that cannot be fully supplemented, assess their actual impact on your tax liability and make the necessary financial arrangements in advance.

Step 4: Optimize the main structure. Is a Hong Kong entity required to handle overseas business? Are the pricing structures for domestic and international markets sound? Are ODI filings and overseas company registrations in compliance? The sooner these structural issues are addressed, the lower the costs will be.

Each of these four steps involves professional challenges, particularly those related to cross-border entities and overseas documentation—it’s very easy to run into pitfalls if you try to figure it out on your own. In response to this round of compliance upgrades for cross-border e-commerce sellers, Qicaiying has launched a bundled service package comprising ”E-commerce Compliance Accounting + Tax Audit Response + Cross-Border Entity Structuring”: E-commerce Compliance Accounting helps sellers organize platform transaction records, match order data, verify payment receipts, and standardize criteria for invoice and revenue recognition; The Tax Audit Response service covers risk control alerts, communication with tax authorities, strengthening the chain of evidence, and follow-up corrective actions; the Cross-Border Entity Structure service facilitates strategic arrangements such as Hong Kong company registration and ODI filing. Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and other locations, as well as annual review audits, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong residency application, renewal, and permanent residency services; Singapore EP application services; and cross-border e-commerce mentoring and managed operations—all as part of our one-stop service. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

IV. Conclusion: Transforming Compliance from a ”Cost Item” into a ”Competitive Advantage”

Looking back at the rapid, unregulated growth of cross-border e-commerce over the past decade, it was driven by first-mover advantages and market dividends; however, competition in the next decade will hinge on ”who can complete the transition to compliance first.” Audit-based taxation is not intended to ”crush” cross-border e-commerce, but rather to propel the industry into a new phase that is healthier and more sustainable—for compliant sellers with transparent accounting, policy incentives will only continue to grow.

The window of opportunity is closing, but it hasn’t closed entirely yet. If you start now to review your accounts, complete your supporting documents, and plan your organizational structure, you still have time to shift your compliance approach from ”reactive” to ”proactive.” Waiting until you receive a notice of audit before taking action will cost you several times what it would cost today.

Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and other locations, as well as services such as annual company audits, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong residency application, renewal, and permanent residency services; Singapore EP application services; and one-stop services such as cross-border e-commerce coaching and managed operations. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add me on WeChat: Qicaiyingjituan).

The Sword of Damocles of regulation has already fallen, but tickets to compliance are still available. Rather than waiting anxiously on the sidelines, take advantage of this window of opportunity to lay a solid foundation—your profits are worth securing steadily through compliance.