In 2026, the cross-border e-commerce industry faced a true “major test of financial and tax compliance.” The old tactics that sellers once relied on to stay afloat—such as “fixed-rate taxation,” “purchasing invoices for customs clearance,” “funds returned to personal accounts,” and “combining 0110 codes with Hong Kong shell companies”—are now being precisely identified through the end-to-end data integration of the Golden Tax Phase IV system. During this year’s tax audit, a Shenzhen-based 3C seller discovered that they had recorded only net cash withdrawals in their books for the entire year, while the total original order amount reported by the platform differed from the revenue on their books by several million. The system immediately triggered a red alert, and the entire team spent an entire quarter compiling supporting documentation.

This is not an isolated case. With the completion of Phase IV of the Golden Tax Project—which has established comprehensive data connectivity among industrial and commercial, tax, banking, social security, customs, and e-commerce platforms—the logic behind financial and tax supervision of cross-border e-commerce has shifted from “post-transaction spot checks” to “real-time, comprehensive data transparency.” More importantly, the industry-wide elimination of assessed taxation by 2026—with all overseas warehouse models subject to audited taxation—means sellers must, like traditional foreign trade enterprises, maintain complete accounting records, compile procurement documentation, and file tax returns independently for each store. Otherwise, any data gaps could become direct leads for tax audits.

For the vast majority of cross-border sellers, compliance is no longer an “option,” but a “matter of life and death” that determines whether they can continue to operate. 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 reviews and audits, bookkeeping and tax filing, tax compliance, business information changes, bank account opening, ODI filing, FDI filing, and other corporate services, as well as 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).

I. 2026: The “Year of the Strictest Regulatory Oversight” for Cross-Border E-Commerce Taxation and Finance: Four Major Changes Take Effect Simultaneously

The reason this year’s fiscal and tax environment has been dubbed the “year of the strictest regulation” is that four key changes took effect almost simultaneously, and when combined, they formed an unprecedented, comprehensive regulatory network.

First, the "Golden Tax Phase IV" initiative has achieved end-to-end data integration. Real-time data sharing has been established among more than 40 departments—including tax authorities, banks, market regulation agencies, social security agencies, customs, public security, housing and urban-rural development, logistics, and e-commerce platforms—covering 138 categories of business data sources. Corporate account transaction histories, personal account transaction histories of legal representatives and shareholders, the number of social security enrollees, water and electricity consumption, logistics orders, e-commerce sales, and real estate information are all included in cross-checks. The system automatically triggers risk alerts for activities such as concealing income through private accounts, logical inconsistencies in purchase and sales invoices, significant discrepancies between revenue and profit, and mismatches between the number of social security enrollees and the number of employees reported.

Second, overseas platforms are required to submit data on a quarterly basis. Pursuant to Announcement No. 15 of 2025 issued by the State Taxation Administration, major overseas platforms such as Amazon, AliExpress, Temu, and independent e-commerce sites are required to submit complete quarterly business data to the relevant domestic authorities, including total order value, refunds, platform fees, and details of payment accounts. At the same time, customs declaration data, bank foreign exchange receipts, and corporate annual tax returns are linked in real time; any discrepancy between platform sales and reported revenue exceeding a reasonable range will trigger a flag.

Third, the industry-wide practice of fixed-rate taxation will be abolished, and all overseas warehouses will be subject to audited taxation. In 2026, the transition period for the fixed-rate tax collection system for cross-border e-commerce will come to a complete end, and a uniform system of audited tax assessment will be implemented for all entities—from individual vendors to industrial and trading groups with revenues in the tens of millions. Sellers who previously filed tax returns based on a fixed profit margin must now fully compile procurement vouchers, inventory records, logistics costs, and platform fees; all revenue, costs, and expenses must be supported by compliant documentation.

Fourth, policy incentives and compliance requirements for the 9810 overseas warehouse model are being strengthened simultaneously. 9810 The “Tax Refund upon Departure” policy provides businesses with a convenient way to recover funds; however, to qualify for this policy, overseas warehouses must be fully registered, customs declaration data must be accurate, and accounting practices must be in compliance with regulations. Sellers operating overseas warehouses who continue to record transactions based on “estimated profits” or “net cash withdrawals” will be the first to face scrutiny during tax audits.

II. Why Have Old Practices Suddenly Become “High-Risk Red Lines”?”

Many sellers are puzzled: Why have practices that worked well in the past suddenly become minefields this year? The answer lies in the fact that regulatory technology has caught up with business models.

“The ”payment and customs clearance plus private account repayment” model has completely failed. Customs has access to export data, while the tax authorities have platform revenue data; when these two sets of figures are cross-checked—if there are sales but no customs declaration, or if the declared value significantly differs from the platform revenue—the scheme is immediately exposed. Even more critical is that the practice of using personal accounts to receive payment for extended periods—while only recording the net amount withdrawn—results in the company’s reported revenue being far lower than the data submitted by the platform, leading the system to automatically flag it as concealed income.

“The ”0110 paired with a Hong Kong shell company” scheme has come under intense scrutiny. In 2026, the State Taxation Administration clarified that it does not recognize the model of “offshore companies with no substantive operations + 0110.” If a Hong Kong company lacks actual office space, staff, and complete financial audit records, and serves purely as a conduit for funds or an entity for issuing invoices, it will be deemed a shell company, and the related business activities may face back taxes, fines, or even criminal liability.

“Procuring goods without invoices and recording them as ”unbilled items' is no longer sustainable." Under the audited assessment system, costs and expenses must be supported by valid documentation. Many sellers are in the habit of using informal receipts, screenshots of WeChat transfers, and third-party payment records for accounting purposes; however, these cannot be recognized as valid costs during tax audits, resulting in inflated profits and a sharp increase in tax liability.

To address the above risks, Qicaiying has launched a comprehensive service package comprising “E-commerce Compliance Accounting + Bookkeeping and Tax Filing + Tax Audit Response”: The E-commerce Compliance Accounting service conducts a specialized review of the consistency between transaction records on cross-border e-commerce platforms and reported data, establishing ledgers for orders, purchases, inventory, and expenses; Bookkeeping and tax filing cover all tax types, including Value-Added Tax (VAT), Corporate Income Tax, and Individual Income Tax; Tax Audit Response assists companies in organizing evidence chains to substantiate the authenticity of their business operations, drafting explanatory statements, and accompanying them during communications with tax authorities. Qicaiying Group specializes in providing company registration services both domestically and internationally, including in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), and the Cayman Islands, as well as annual reviews and audits, bookkeeping and tax filing, tax compliance, information updates, bank account openings, ODI filings, FDI filings, and other corporate services; Hong Kong residency applications, renewals, and permanent residency services; Singapore EP application services; and cross-border e-commerce support and agency services. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

III. Compliant Accounting Records Under the Audit-Based Taxation System: Four Statements Sellers Must Maintain

The key change in switching from a fixed-rate tax assessment to an audited-accounts tax assessment is the shift from “estimating profits” to “calculating profits.” Companies must establish the following four basic ledgers; otherwise, the data reported will not be consistent.

First: Order Ledger. Record the platform order number, transaction time, buyer’s actual payment amount, refund amount, platform commission, shipping costs, and receiving account for each order. The taxable base must be based on the buyer’s original total payment amount for the order; platform commissions, overseas warehousing fees, and marketing fees are considered operating costs and cannot be directly deducted from revenue.

Second: Procurement Ledger. For each shipment: the supplier, purchase contract, invoice or valid supporting documentation, payment records, warehouse receipt records, and corresponding sales order. For purchases made without an invoice, the supporting documentation must be provided or an invoice obtained through compliant channels; otherwise, the expense cannot be deducted for tax purposes.

Page 3: Inventory Ledger. Inventory in overseas warehouses, inventory in transit, and inventory in domestic warehouses must be physically counted on a regular basis, and the inventory management system must be consistent with the financial records. Under the 9810 overseas warehouse model, all stages—including goods leaving the country, entering the warehouse, sales, and returns—must be supported by documentation.

Page 4: Expense Ledger. All expenses—including advertising fees, warehousing fees, logistics fees, monthly platform fees, software tool fees, and employee salaries—must be recorded based on actual costs and supported by compliant invoices or valid documentation. It is especially important to note that if overseas expenses are paid through a third party, you must retain the complete chain of documentation, including contracts, invoices, and payment records.

IV. A Three-Step Implementation Plan: From “Firefighting” to “Fire Prevention”

In the face of stricter regulations, the biggest mistake sellers can make is to “treat the symptoms rather than the root cause.” The truly effective approach is to establish a routine compliance firewall.

Step 1: Conduct a self-inspection of existing business operations and obtain the necessary documentation. Compare the platform’s sales data, customs declaration data, and bank statements from the past three years to verify, on a month-by-month basis, any discrepancies between recorded revenue and actual revenue; for historical issues such as purchases without invoices, payments received through personal accounts, and inventory discrepancies, develop plans to provide supporting documentation or implement corrective measures, and complete self-corrections before the tax authorities initiate an audit.

Step 2: Restructure the financial accounting system. Maintain separate accounts by store, entity, and currency to ensure independent accounting for each taxable entity; integrate platform backend data, the ERP system, and financial software to ensure consistency across the four flows: orders, procurement, inventory, and funds; standardize invoice management so that all issuance, receipt, credit memos, and archiving comply with digital invoice requirements.

Step 3: Establish a mechanism for ongoing compliance. Regularly review whether tax rates, gross profit margins, and expense ratios are reasonable; stay informed about the latest announcements from the State Taxation Administration and the General Administration of Customs; and conduct a compliance assessment before expanding operations, restructuring, or repatriating funds to avoid new risk exposures arising from the establishment of new entities or platforms.

The stricter the regulations, the deeper the moat for compliant companies. The Fourth Phase of the Golden Tax Project is not intended to “eliminate” cross-border e-commerce, but rather to weed out players who survive through gray-market practices, leaving market opportunities for companies that operate in full compliance. 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 more. We also offer corporate annual review and auditing, bookkeeping and tax filing, tax compliance, information updates, bank account openings, ODI and FDI filings, as well as other corporate services; Hong Kong residency applications, renewals, 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).

In 2026, the competition in cross-border e-commerce will no longer be about “who can get around the rules,” but rather “who can navigate them steadily.” Maintaining accurate financial records, preserving a complete chain of evidence, and ensuring compliant declarations are the true foundations for weathering regulatory cycles.