The year 2026 is referred to by the industry as the ”first year of financial and tax regulation for cross-border e-commerce.” With the full rollout of the Golden Tax Phase IV system, data from multiple departments—including industry and commerce, taxation, banking, social security, customs, and payment services—has been fully integrated across the entire supply chain. This means that the ”information asymmetry” moat on which cross-border e-commerce sellers once relied has been completely eliminated—sales data from overseas warehouses, foreign exchange remittance routes, bank transaction details, and social security payment records are all now within the scope of tax supervision. An even more significant change is that tax authorities in many regions have officially announced the complete elimination of fixed-rate taxation for sellers operating under the overseas warehouse model, replacing it with audit-based taxation. This means that long-standing gray-area practices in the cross-border e-commerce industry—such as ”0110 exports + private account receipts,” ”fictitious export invoices,” and ”profit diversion via Hong Kong shell companies”—have officially become high-pressure red lines subject to tax audits.

The case of a major Shenzhen-based seller is causing a ripple effect throughout the industry. With an annual GMV of approximately 300 million RMB, the seller had long been using the ”0110” general trade export customs clearance procedure. The goods were actually shipped to overseas warehouses in the United States for sale, and the proceeds were intercepted through a Hong Kong company account before being split and transferred to multiple private accounts within China. In June 2026, tax authorities used the Golden Tax Phase IV system to conduct a cross-check and discovered that the seller’s declared export value did not match the amount received in its corporate account; the number of employees reported for social security contributions was significantly inconsistent with the actual size of the warehousing team; and the bank transaction records showed numerous suspicious patterns of “overseas remittances followed by split transfers.” Ultimately, the seller was required to pay back taxes and late payment penalties totaling over 8 million yuan and faces fines ranging from 0.5 to 3 times that amount. This is not an isolated case but a signal of a fundamental shift in industry regulation. The 9810 cross-border e-commerce export model is becoming the only compliant pathway.

There is no turning back when it comes to cross-border e-commerce financial and tax compliance; every step—from export customs clearance to profit repatriation—requires professional support. 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), and the Cayman Islands, as well as annual reviews and audits, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong residency applications, renewals, and permanent residency services; Singapore EP application services; and one-stop services such as cross-border e-commerce coaching and agency operations. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

I. Full-Chain Integration of the Fourth Phase of the Golden Tax System: Data Profiles of Cross-Border Sellers

To understand this major regulatory shift, we must first clarify the specific meaning of the ”full-chain integration” under the “Golden Tax Phase IV” initiative.

Data sharing among six departments. Phase IV of the Golden Tax Project has achieved data interoperability across six sectors: Industry and Commerce (business registration information, shareholder structure, and change records); Taxation (invoice data, tax returns, and tax refund records); banking (corporate account transaction histories, large-value transaction alerts), social security (number of employees, contribution bases), customs (customs declarations, export tax rebates), and payments (data from third-party payment platforms, cross-border payment receipt records). For cross-border sellers, this means that your sales data on Amazon, payment records from Wanlihui, export data from customs declarations, repayment amounts in corporate bank accounts, the number of warehouse staff, and social security information—all of this information forms a complete, cross-verified closed loop within the tax system.

Automated risk alerts. The Golden Tax Phase IV system incorporates more than 200 risk warning indicators. For cross-border sellers, the most critical indicators include: the consistency between export value and payment receipts (a discrepancy exceeding 20% triggers an alert); the ratio of payments received in corporate accounts versus personal accounts (if payments to personal accounts exceed 30%, the account is flagged as high-risk); consistency between customs-declared product descriptions and actual sales categories; and alignment between the number of social security enrollees and business scale. Once the system detects an anomaly, it automatically generates a risk task and forwards it to the competent tax authority, enabling audit personnel to conduct targeted investigations based on this information.

"See-through" regulation has been implemented. Phase IV of the Golden Tax System has the ability to see through corporate equity structures. Tactics that previously circumvented regulation through multi-tiered offshore companies and nominee holding structures are no longer effective. The system can penetrate multi-layered equity relationships to identify actual controllers and beneficial owners, thereby attributing overseas profits to domestic entities. This means that practices involving the diversion of profits through Hong Kong shell companies and their subsequent repatriation to the mainland under the guise of ”investment funds” will face comprehensive tax audits.

II. Three Major High-Risk Red Lines: Practices That Were Acceptable in the Past Must Now Be Stopped

Under the end-to-end oversight of the Golden Tax Phase IV initiative, the following three operational models have been explicitly identified as key targets for tax audits, and cross-border sellers must complete self-inspections and make necessary corrections as soon as possible.

Red Line 1: Using the 0110 scheme in conjunction with a Hong Kong shell company to divert profits. This is the most common gray-market scheme: Sellers declare exports under the ”0110” general trade category, but the goods are actually sold overseas through overseas warehouses. The proceeds from these sales are deposited into the accounts of Hong Kong shell companies, and only a portion of the funds is transferred back to domestic corporate accounts under the guise of “export proceeds,” while the remaining profits are retained in Hong Kong over the long term. The Golden Tax Phase IV system can accurately identify the amount withheld by comparing the declared export value with the corporate repayment amount. Once verified, profits withheld in Hong Kong will be deemed concealed income of the mainland enterprise, resulting in the collection of corporate income tax and late payment penalties; in severe cases, the enterprise may be convicted of tax evasion.

Red Line 2: Payments from Private Accounts. Many cross-border sellers routinely transfer Amazon proceeds through payment platforms such as Wanlihui and Payoneer into the personal bank accounts of corporate legal representatives or shareholders, and then split the funds into multiple personal accounts. The bank data integration feature of the ”Golden Tax Phase IV” system can automatically identify suspicious transaction patterns characterized by "incoming overseas transfers—frequent splitting—large cash withdrawals." The People’s Bank of China’s anti-money laundering system—which includes Large Value Transaction Reports (for cross-border remittances exceeding 50,000 yuan per transaction) and Suspicious Transaction Reports—has established data sharing with the tax system. Transferring proceeds to personal accounts not only poses the risk of having to pay back taxes but may also trigger anti-money laundering investigations.

Red Line 3: Export on a buy-side basis. Some sellers do not have import-export rights and export goods by purchasing customs declaration documents from other companies. Under the “Golden Tax Phase IV” system, anomalies—such as inconsistencies among the exporting company, the actual owner of the goods, and the payment account listed on the customs declaration—can be automatically detected by the system. Purchasing customs declaration documents to export goods not only prevents compliant application for export tax rebates but may also be deemed an attempt to fraudulently obtain export tax rebates, resulting in criminal liability.

Every step of the process—from export customs clearance to the repatriation of profits—requires a compliant structure; cross-border sellers can no longer operate in a “gray area” and bear “black-market” risks. 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 offer a one-stop range of corporate services, including annual reviews and audits, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong identity application, renewal, and permanent residency services; Singapore EP application services; and cross-border e-commerce mentoring and agency 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).

III. 9810: The Only Path to Compliance and Key Policy Benefits

Given the current system of comprehensive audit-based taxation, the 9810 cross-border e-commerce export model is currently the only compliant pathway that allows businesses to benefit from policy incentives.

The core mechanism of the 9810 model. Customs supervision mode code 9810, officially known as ”Cross-border E-commerce Exports to Overseas Warehouses,” refers to the process where domestic enterprises export goods to overseas warehouses via cross-border e-commerce, and then sell those goods to overseas consumers from those warehouses. Unlike the 0110 general trade export, the 9810 code is specifically designed for cross-border e-commerce scenarios, and its customs declaration, foreign exchange settlement, and tax refund processes are highly aligned with the cross-border e-commerce business model.

Tax-Exemption Policy for Travelers Without Tickets. Under the 9810 model, if a seller is unable to obtain a special VAT invoice when purchasing goods, the seller may, in accordance with regulations, benefit from the ”tax exemption without an invoice” policy—that is, VAT is exempted at the export stage, and the tax exemption, credit, and refund mechanism does not apply. This resolves the widespread issue of missing invoices that cross-border e-commerce sellers commonly face when purchasing from small and medium-sized suppliers, enabling export sales without input invoices to operate in compliance with regulations.

Advance Tax Refund Mechanism. Under the 9810 model, eligible cross-border e-commerce enterprises can benefit from the export ”advance tax refund” policy—allowing them to apply for a refund of input VAT at a specified rate after the goods have been cleared for export but before actual foreign exchange receipts are received. This significantly shortens the tax refund cycle and improves corporate cash flow. However, the advance tax refund places extremely high demands on enterprises’ accounting compliance—they must establish comprehensive ledgers covering the entire supply chain, including procurement, inventory, sales, and foreign exchange receipts, to ensure that the input tax, customs declaration, logistics, and foreign exchange receipt data for each export transaction are traceable.

The Four Elements of a Compliance Framework. The 9810 model requires sellers to establish a comprehensive compliance framework: First, the store’s operating company must be registered separately and not commingled with other business operations; second, the store’s operating company must open a corporate bank account, and all platform payments must be deposited into that account; Third, profits must be repatriated compliantly through the corporate bank account and may not be transferred via personal accounts; fourth, if a Hong Kong company acts as an intermediary trading entity, it must demonstrate commercial substance—including a business address, full-time employees, and independent accounting—otherwise it may be deemed a conduit company, and the profits will still be attributed to the mainland entity.

IV. From the Gray Area to Compliance: The Second Half of Cross-Border E-Commerce

The major changes in financial and tax regulation for cross-border e-commerce in 2026 mark the end of the industry’s era of ”unchecked growth.”

Over the past decade, the rapid growth of cross-border e-commerce has largely been built on gray-area tax practices—the low tax burden resulting from fixed-rate taxation, the financial flexibility provided by funds returned to personal accounts, and the operational convenience of export transactions through third-party payment services have collectively formed the ”gray-area benefits” for cross-border sellers. However, this dividend was essentially a time window created by regulatory lag; with the full rollout of the Golden Tax Phase IV system, this window has now closed.

Compliance is not a cost—it is a competitive advantage. Sellers who have completed the implementation of the 9810 compliance framework can not only benefit from tax exemptions for transactions without invoices and advance tax refund policies but also gain compliance-based endorsement for bank credit lines, capital connections, and market expansion. Sellers who remain in a gray area, however, face not only the risk of back taxes and fines but also the potential loss of supply chain and channel partnership opportunities as platforms tighten compliance requirements and supplier invoice management becomes more standardized.

From establishing a 9810 compliance framework to ensuring business substance for Hong Kong companies, and from export tax rebates to the compliant repatriation of profits, cross-border sellers require one-stop professional services to support their financial and tax compliance. Qicaiying Group specializes in providing company registration services for domestic and international locations, including 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 review and auditing, 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).

In the next phase of cross-border e-commerce, the competition will no longer revolve around the audacity to engage in gray-area practices, but rather on the professionalism of compliance frameworks. Sellers who complete the 9810 transition ahead of schedule will gain a firm foothold amid this regulatory shake-up; those who remain on the sidelines, however, may soon discover that the data profiling under the Golden Tax Phase IV system has precisely pinpointed every gray-area route. The window for compliance transformation won’t remain open forever—the sooner you act, the lower the cost.