In 2026, cross-border e-commerce exports to overseas warehouses (Customs supervision code 9810) will continue to be eligible for ”tax refunds upon departure.” Exports under code 9810 in Guangdong and other regions have surged nearly tenfold, and many sellers have breathed a sigh of relief after receiving advance tax refunds that have eased their cash flow.

But advance tax refunds aren’t free—there’s a strict ”settlement” requirement that must be met. If you don’t complete the settlement by the deadline, the tax authority will reclaim the advance tax refund in full. Today, I’ll explain this settlement process in detail.

01

How Does the "Tax Refund Upon Departure" Program Work?

According to Announcement No. 3 of 2025 issued by the State Taxation Administration, goods shipped to overseas warehouses under tariff code 9810 may be declared for export tax refunds (or exemptions) immediately after customs clearance for export.

For goods that have already been sold, refunds shall be processed in accordance with current regulations; for goods that have not yet been sold, an advance export tax refund shall be processed under the principle of ”tax refund upon departure, with final settlement upon sale,” and the transaction type shall be designated as HWC-YT.

In the ”Tax Refund (Exemption) Transaction Type” column of the detailed declaration form, enter ”Overseas Warehouse Pre-Refund.” Manufacturing enterprises and foreign trade enterprises must each file their declarations using separate declaration numbers and separate reference numbers.

02

The accounting period is a sword of Damocles

For taxpayers who have applied for an advance tax refund, the accounting must be completed during each VAT filing period prior to the end of the accounting period. The accounting period runs from the first day of the month following the month in which the tax authority finalized the advance tax refund through April 30 of the following year.

All Sales: Compare the estimated tax refund with the actual tax amount; if the estimated refund exceeds the actual tax, the excess will be refunded; if the estimated refund is less than the actual tax, the difference must be paid. Partial Sales: Recognize the sold portion; return the estimated tax refund for the unsold portion. Unsold: Return the full amount; refile after the goods are sold.

If you fail to file your tax return by the deadline, the tax authorities will recover the advance tax refund. In the worst-case scenario, the advance tax refund effectively becomes a short-term, interest-free loan, and you’ll have to pay the money back.

03

Tax-Free Returns Serve as a Safety Net

Goods exported between 2026 and 2027 that are re-imported in their original condition within six months are exempt from import duties and value-added tax (provided that any previously refunded tax amounts are first repaid).

This is a real safety net for the 9810: Previously, high tariffs had to be paid on unsold inventory returned from overseas, but now the cost of returns has been significantly reduced.

It is recommended that customs brokers create a ”Preliminary Tax Refund Ledger” for 9810 clients: Record the declared value, preliminary tax refund amount, overseas sales progress, and accounting cutoff date for each customs declaration form, and remind clients two months in advance to prepare the necessary documents.

04

A Five-Step Process

Regardless of the model, the core process for export tax rebates is the same: obtain a special VAT invoice → file a customs declaration to obtain a customs declaration form → clear foreign exchange receipts → submit the tax return via the Electronic Tax Bureau → review and post to the books.

Important Reminder: Effective July 30, 2026, China e-Port will no longer support the online printing of tax refund-specific customs declarations. Data will still be transmitted to the tax authorities, and you can download customs declarations with electronic signatures via the Single Window platform for archiving.

Documents must be retained for ten years; purchase and sales contracts, transport documents, and customs declaration authorization documents are all required. The information on the “three documents” (customs declaration, bill of lading, and invoice) must match; otherwise, the shipment will be subject to taxation.

9810 is a channel that offers benefits for compliant cross-border business operations, but ”refund upon departure” is followed by ”re-accounting of sales.” Only by keeping track of the ledgers and adhering to the deadlines can you truly realize those benefits.

Scan the QR code to add Qicaiying’s online customer service

—— E N D ——