Many sellers who operate multiple store groups follow this practice: they have several stores, each linked to a different company. Some are registered under their own ID cards, some under friends’ names, and some under relatives’ names. Payment collection is even more chaotic—some funds are transferred to personal bank accounts in mainland China, some go into Hong Kong company accounts, and some are left directly in the platform’s wallet.

You might not even know yourself which company corresponds to which store, or which payment account corresponds to which entity.

Some sellers believe this “spreads the risk”—keeping sales below 5 million for each business to maintain small-scale taxpayer status. That is, until 2026, when “penetrative supervision” goes into effect, and the tax authorities will be able to pinpoint each business with pinpoint accuracy by analyzing IP addresses, warehouses, cash flows, and relationships between legal representatives.

Those strategies designed to “diversify risk” may actually be turning into “concentrated risk.”

If your business operates multiple stores through three or more separate legal entities, or if you have both a domestic company and a Hong Kong company but lack a clear organizational structure, please scan the QR code to contact customer service.WeChat: qcygscszk 📞 Phone: 18676749275, with the note “Architecture Diagnosis,” to help you identify potential risks in your current architecture.

01 Get the facts straight first::Why are problems now arising with the multi-entity approach?

Previous Environment: Multiple stores correspond to multiple companies; each company files its own tax returns and maintains its own accounting records, and the tax authorities do not proactively link these entities. Even if one company files a zero return, another reports a loss, and yet another reports a profit, they remain “invisible” to one another.

Change No. 1: Full implementation of “entity-based” supervision.

In 2026, tax authorities will aggregate the revenue of multiple entities under the same actual controller by analyzing multi-dimensional information, including IP addresses, warehouse addresses, cash flow, and relationships between legal entities.

Change No. 2: The State Taxation Administration has, for the first time, clarified the guidelines for handling the multi-store model.

On April 7, 2026, an internal guideline circulating among sellers—titled “Guidelines on Tax-Related Issues for Cross-Border E-Commerce Enterprises”—was released. Although not an officially published document outlining tax incentives, it provided guidance on compliance for the long-standing “multiple stores, single accounting” model. The guidelines clearly state that the store entity is the taxpayer. If multiple stores are managed by a single operating entity under a unified accounting system, common costs may be allocated to each store using the “revenue proportion method.”

Have an impact: The previous practice of using multiple entities to spread out revenue in order to “keep each entity’s revenue below 5 million” is no longer effective. After the consolidation of ownership, the actual revenue from all stores is now aggregated under a single controlling party.

02 What specific problems does a disorganized architecture cause?

A lack of clarity in the multi-company, multi-store structure leads to at least three problems:

First, a misalignment of responsibilities has led to the deadlock of “revenue without costs.”

Many sellers adopt a structure in which the “store entity and the operating entity are separate”: the platform store is registered under Company A, while actual procurement, operations, and fund consolidation are handled by Company B. The result is that the store entity has revenue but no costs, while the operating entity has costs but no revenue. This misalignment of entities can no longer be circumvented following the implementation of the Value-Added Tax Law.

From the tax authorities' perspective: Company A has revenue but no costs—its profits are artificially inflated, so it must pay taxes; Company B has costs but no revenue—it is operating at a continuous loss. Once a thorough investigation is conducted, this is deemed to be artificial profit manipulation.

Second, there is confusion regarding the allocation of costs and expenses.

Headquarters procurement, advertising, and logistics costs—which company’s expenses do these fall under?

Many sellers operate by listing their products on Company A one month and Company B the next, with absolutely no consistent pattern. Although internal guidelines allow for the allocation of shared costs—such as advertising fees, shipping costs, and warehousing fees—to individual stores using the “revenue proportion method,” this is contingent on having a traceable and verifiable basis for allocation, along with supporting ledgers. In the eyes of the tax authorities, allocation without clear rules is considered an artificial adjustment of profits.

Third, potential tax compliance risks associated with offshore entities such as Hong Kong companies.

Receiving payments through a Hong Kong company but failing to file taxes in Hong Kong, or having a mainland company file a “zero-report” while actually conducting business on the mainland—such “half-baked” arrangements will be a key focus of audits by tax and foreign exchange authorities in 2026.

Failure to file tax returns for a Hong Kong company = back taxes + fines + potential blacklisting if discovered. A mainland Chinese company with zero tax returns but actually operating in mainland China constitutes a permanent establishment and must pay taxes at the mainland tax rate.

03 How do you set up a multi-entity architecture?

The core idea is not to “reduce the number of companies,” but rather “Clear Division of Responsibilities” and “Traceability of Funds and Business Flows” . True “one-to-one correspondence” means that each store’s revenue, costs, inventory, and funds can be clearly and compliantly attributed to its registered entity.

Most cross-border e-commerce businesses operate multiple store networks and often adopt a consolidation model for financial and tax compliance. A relatively mature structure could be designed as follows:

① Retail Companies (N) 

Register N separate domestic companies, with each company registering one store on an e-commerce platform. This is the starting point for the “one-to-one correspondence.”

② Operations/Export Company (1)

Establish one core domestic company to oversee key operations such as centralized procurement, export customs clearance, operations, and marketing.

③ Entity responsible for consolidating overseas funds (1)

Establish one Hong Kong company to serve as a hub for fund transfers and consolidation.

④ Unified Holding Platform (Recommended)

If conditions permit, a unified holding platform could be established to hold the brands of each store and manage foreign currency accounts, thereby enabling centralized management.

04 How do funds and business flows move?

The ingenuity of this architecture lies in its ability to establish a one-to-one correspondence between “stores, accounts, companies, and funds” through a clear transaction chain. The complete path is as follows:

1. Consumer Payment: A consumer places an order and makes a payment at “Store A.”

2. Platform Settlement: The e-commerce platform will settle the payment to the corporate account associated with “Store A” (via a third-party payment processing tool).

3. Consolidation of Funds: “Store A” pays revenue (in the form of service fees or payment for goods) to the “Operations/Export Company” and the “Hong Kong Company.”

4. Retained Earnings: Profits can ultimately be retained in compliance with regulations within the “Hong Kong company” or repatriated to the mainland parent company through dividends or other means.

The key point is that the flow of funds must align with the substance of the business.::

“The revenue of the ”Store Company“ (platform settlement payments) constitutes the consideration for its procurement of goods or services from the ”Operations Company.“ The revenue of the ”Operations Company“ consists of service fees charged for providing operations, procurement, logistics, and other services to the ”Store Company.“ The revenue of the ”Hong Kong Company” consists of reasonable profits generated in its capacity as an overseas procurement and trading entity.

05 Chain of Evidence(math.) genusThe most crucial step

Having only a corporate structure and cash flow is far from sufficient; you must prepare a complete chain of evidence in case tax authorities conduct a thorough audit. This chain of evidence includes:

Proof of Shareholding: Use an equity ownership chart to clearly illustrate the ownership relationships between companies, demonstrating that all store companies are controlled by the same group.

Business Agency Agreement: Each “store company” signs a “Store Operation Authorization Agreement” or “Service Agreement” with the “operating/export company,” clearly defining the scope of services and pricing.

Related-Party Transaction Pricing Documentation: Prepare a detailed transfer pricing report to demonstrate that related-party transactions (such as service fees) comply with the arm’s-length principle and are fairly priced.

“Documents Reflecting the ”Alignment of the Three Flows”: Ensure that the entity names on the contract (agreement), invoice, and payment receipt (bank statement) are exactly the same. For example, when Store A pays a service fee to the operating company, the contract, invoice, and payer must all be Store A.

Transaction Ledger: Regularly organize and file bank statements and platform settlement records by store number.

06 Four Pitfalls Sellers Must Avoid

Pitfall 1: Commingling of Income.

Avoid at all costsRevenue from the five stores is deposited into the same personal or business account. The receiving account for each store must correspond to its registered business entity.

Pitfall #2: Misalignment of the subject.

Ensure that the entity names on the platform settlement statements, purchase invoices, and customs declarations are exactly the same.

Pitfall 3: The “Zero-Declaration” Trap.

If a store or company has actual revenue, it can no longer file a “zero return.” It must maintain separate accounting records and file returns based on the actual revenue reported by the platform.

Pitfall 4: Learning only the “shell” of "Saiwei" without grasping its essence.

Many sellers claim to follow the “Saiwei Model,” but they’ve only copied the shell—not the essence. The true Saiwei Model has always adhered to compliance—eliminating shell companies, paying back taxes, and ensuring that every store engages in substantive business operations. If you simply register a bunch of shell companies without any evidence of actual business operations or independent accounting records, it will still be deemed an illegal business fragmentation.

07 Here are the four things you need to do right now

Step 1: Clean up dormant stores.

Companies that own stores but do not actually operate them must either be dissolved or transition to active operations.

Step 2: Create an allocation ledger.

Using the revenue-based allocation method, allocate shared costs such as advertising and logistics fees to each store to maintain a basis for calculation.

Step 3: Organize the chain of evidence.

Procurement contracts, payment records, logistics documents, and platform fee statements are compiled to form traceable records for reference.

Step 4: Verify the platform data.

Ensure that the revenue recorded in the platform's backend matches the revenue reported for tax purposes.

If you operate multiple stores through three or more business entities, or if you have both a domestic company and a Hong Kong company but lack a clear structural plan, you can scan the QR code to add us.WeChat: qcygscszk 📞 Phone: 18676749275, with the note “Architecture Diagnosis.” We’ll help you with two things:

• First, analyze each company’s functional roles, revenue allocation, and current cost allocation practices to identify transfer pricing risks and look-through risks;
• Second, based on the structural model approved by the State Taxation Administration, provide specific optimization recommendations and implementation steps.

08 What can Qi Cai Ying do for you?

Qicaiying has extensive experience in planning multi-entity structures for cross-border e-commerce and can help you:

① Compliance Assessment of Multi-Stakeholder Architectures
Analyze each company’s functional positioning, revenue attribution, cost allocation, and profit distribution to identify transfer pricing risks and piercing-the-veil risks.

② Setting Up a Reconciliation Ledger Using the Revenue Allocation Method
In accordance with the cost allocation method approved by the State Taxation Administration, establish a unified accounting system for multiple stores to ensure that the tax returns filed by each entity are verifiable and supported by evidence.

③ Related-Party Transactions: Pricing and Transfer Pricing Documentation
Assist in preparing compliant transfer pricing reports and service agreements to demonstrate that related-party transactions comply with the arm’s-length principle.

④ Establishing Compliance Frameworks for Cross-Border Entities
Assist Hong Kong companies with tax filing and audits, design compliant transaction structures between mainland and Hong Kong companies, and optimize the entire process—from contracts and invoices to foreign exchange payments.