First Cross-Border Tax Industry Guidelines Released: Cross-Border Sellers’ Logistics Chains Fully Incorporated into Standardized Regulation
Published: August 20, 2026
When it comes to cross-border e-commerce, many sellers used to think that financial and tax compliance simply meant “reporting revenue and paying taxes on time.”
But now it's becoming less and less that simple.
Procurement, logistics, customs clearance, platform orders, overseas warehouses, cross-border collections, foreign currency payments, export tax rebates… Every step in the process can become part of the chain of evidence during a tax audit.
Cross-border sellers—especially those who operate through multiple entities, use overseas warehouses, settle transactions through overseas companies, and rely on overseas logistics services on a long-term basis—need to re-examine their business operations.
Judging from policy changes in recent years, one very clear trend is:
Tax and financial compliance in cross-border e-commerce is shifting from “point-by-point reporting” to “end-to-end verification of business operations.”
1,What cross-border sellers really need to focus on is more than just “how much tax to pay”
Let’s first look at a cross-border e-commerce transaction:
In the past, companies may have focused on only one or two of these stages.
But what really matters now is:
Can these data sets be matched up with each other?
Where does the merchandise come from?
Who is in charge of procurement?
Who handles customs clearance?
Who is selling it?
Who's taking the money?
Who pays for shipping?
Who recognizes revenue?
Who files for a tax refund?
If these issues cannot form a complete chain of evidence, the company’s financial and tax risks will continue to rise.
2,Logistics is no longer just about “shipping costs”; it has become a crucial component of the financial and tax chain.
In the past, many cross-border sellers handled shipping costs very simply:
The freight forwarder provides a total quote → The company makes the payment → Receives a logistics invoice → The accounting department records the transaction.
However, for cross-border e-commerce businesses, shipping costs are often linked to both:
Therefore, when reviewing logistics documentation, one cannot simply look at whether or not there is an invoice.
We should focus more on:
① Is the contract genuine?
With whom did the company sign the contract?
Who is the actual carrier?
What is the relationship between freight forwarders, shipping lines, and overseas warehouses?
② Can the transport route be reconstructed?
Where are the items shipped from?
Where does it go through?
Where will it end up?
Which shipment does this correspond to?
③ Are the logistics costs aligned with the business?
For example:
Logistics Contract → Bill of Lading/Waybill → Customs Declaration → Purchase Order → Payment History
Ideally, a one-to-one correspondence should be established.
This is why cross-border businesses increasingly need to establish their ownLogistics Document ArchivesThe
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3. Overseas Remittances: Amounts exceeding $50,000 do not automatically trigger a deduction of “10%.”
This is something that many cross-border sellers tend to get confused about.
Current publicly available tax regulations clearly state:
Domestic institutions and individuals may make a single payment to overseas entities equivalent to$50,000 or moreFor certain funds related to trade in services and investment income, tax filing for outbound payments for trade in services and other projects is required, except in cases where filing is exempted as specified.
This explicitly includes income derived by foreign entities or individuals from within the countryRevenue from trade in services, including transportation, tourism, telecommunications, insurance, finance, and computer and information services. The procedural guidelines published by the tax authorities in 2026 continued to follow this rule.
But keep in mind:
$50,000 is a key threshold for “tax filing for overseas payments,” but it does not mean that “any amount exceeding $50,000 will automatically be subject to a 10% tax.”
What really needs further consideration is:
What exactly is the nature of this money?
Is this for purchasing goods?
International shipping?
Rent?
Service fee?
Technical Services?
Commission?
Or is it other nonresident income?
The tax treatment varies depending on the nature of the transaction.
Therefore, cross-border sellers should not simply assume that:
“As long as you pay an overseas logistics company more than $50,000, 10% will be deducted automatically.”
The correct way to do this is:
First, determine the nature of the transaction → determine the source of the tax → determine the tax treaty benefits → determine whether there is a withholding obligation → then complete the filing and reporting.
The State Taxation Administration has also clearly outlined procedures for managing information on cross-border transaction contracts, collecting information on non-resident enterprises, and filing corporate income tax withholding returns. (State Taxation Administration of China)
4,Why Should “Overseas Logistics Payments” Be a Priority for Inspection?
Since cross-border sellers make payments to overseas companies, they have essentially entered:
Tax Administration Scenarios for Non-Resident Enterprises.
For example, when a company pays fees for transportation, services, or other expenses to an overseas service provider, it must determine:
What kind of company is the other party?
What exactly are the services being offered?
Where does the service take place?
Is the income considered to be derived from sources within China?
Does a tax treaty apply?
Is withholding required?
Is it necessary to file a tax registration for overseas payments?
The operational guidelines for cross-border payments released by the State Taxation Administration clearly state that enterprises can use the Electronic Tax Bureau toCollection of Nonresident Enterprise Identification Information, Management of Cross-Border Transaction Contract Information, and Corporate Income Tax Withholding and Reporting.(State Taxation Administration of China)
So:
“The overseas payment has been completed” ≠ “The tax matters have also been completed.”
This is an aspect that cross-border businesses often overlook.
5,The VAT treatment of logistics services cannot be handled with a simple “one-size-fits-all” approach.”
Another point that’s often misunderstood is:
“Can all invoices issued by freight forwarders be treated as international transportation services?”
The answer isn't simply “yes.”
Current VAT policies clearly stipulate that domestic entities or individuals sellingInternational Shipping ServicesA zero VAT rate applies; eligible cross-border taxable transactions may benefit from the corresponding zero-rate policy in accordance with regulations. The State Taxation Administration has also clarified that for cross-border taxable transactions subject to the zero-rate policy, zero-rate invoices must be issued truthfully in accordance with regulations. (State Taxation Administration of China)
So what companies really need to determine is:
What type of service does this transaction actually fall under? Who is the actual provider? How is it defined in the contract? What is the substance of the transaction?
Rather than simply looking to see if the invoice includes the words “international logistics” or “international transportation.”
This is why cross-border sellers today can’t just compare prices when choosing a freight forwarder.
It is equally important to ensure that the contract, quotation, invoice, shipping documents, and customs declaration documents are consistent with one another.
6,Export Tax Rebates: A Significant Benefit for Cross-Border Sellers Since 2025
The fact that logistics compliance is becoming increasingly detailed does not mean that policies are only “tightening.”
On the contrary, export tax rebate policies are also being continuously optimized to accommodate the new business models of cross-border e-commerce.
In 2025, the State Taxation Administration issued the “Announcement of the State Taxation Administration on Matters Concerning Support for the Development of Overseas Warehouses for Cross-Border E-Commerce Exports and Export Tax Rebates (Exemptions),” which stipulates:
For the 9810 cross-border e-commerce export model to overseas warehouses, the principle of “tax refund upon departure, with tax recalculation upon sale” can be implemented.
In other words, after goods have been cleared for export under code 9810, an application for an export tax refund (or exemption) may be filed provided the relevant requirements are met; if the goods have not yet been sold, an advance export tax refund may be processed first, with final calculations made later based on actual sales. (State Taxation Administration Policy and Regulations Database)
This is for:
Amazon, Temu, Independent Websites, Overseas Warehouses, Multi-Country Markets
For companies, this is a policy change that warrants close attention.
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7,However, “tax refund upon departure” does not mean “you can receive payment immediately upon export.”
There is also a very important misconception here.
The “tax refund upon departure” policy implemented for 9810 exports to overseas warehouses does not mean that:
Once the goods are shipped, the company no longer needs to handle subsequent sales.
On the contrary, follow-up accounting remains very important.
The State Taxation Administration has clarified:
If an item includes both goods that have already been sold and goods that have not yet been sold, they must be treated separately.
Sold PortionProcess export tax refunds (or exemptions) in accordance with current regulations;
Unsold PortionYou may apply for an advance export tax refund, which will be settled later based on actual sales. (State Taxation Administration of China)
Furthermore, advance tax refunds are not simply a matter of “issuing a refund and being done with it.”
Tax authorities have already provided relevant data to taxpayers through systems such as the Electronic Tax Bureau and the “Single Window” for International Trade; enterprises are required to perform subsequent accounting based on their actual sales. (State Taxation Administration of China)
So, for sellers using overseas warehouses:
Tax refunds are just the first step; follow-up sales accounting is what closes the loop.
8,In 2026, another change that cross-border sellers cannot afford to ignore has emerged: export returns.
In February 2026, the Ministry of Finance, the General Administration of Customs, and the State Taxation Administration issued an announcement granting temporary tax incentives for returned cross-border e-commerce export goods.
From January 1, 2026, through December 31, 2027, eligible cross-border e-commerce export goods declared for export under customs supervision codes such as 1210, 9610, 9710, and 9810 will, due toSlow-moving inventory, returnsFor reasons such as [...], goods returned to their original condition and re-exported within the prescribed time limit are eligible for corresponding import tax incentives. (State Taxation Administration Policy and Regulations Database)
However, if an export tax refund has already been processed for this shipment:
The company must make up the refunded tax amount in accordance with regulations.
At the same time, companies must also prepare materials such as export customs declarations/declaration lists, statements explaining the reason for the return, and platform records of returns or refusals. (State Taxation Administration Policy and Regulations Database)
What does that mean?
“Returns” in cross-border e-commerce have also entered a closed-loop financial and tax system.
We can no longer simply interpret this as:
Platform Refund → Return to Overseas Warehouse → Reshipment
9,There is another risk that many companies overlook: double taxation abroad.
As companies increasingly use:
Hong Kong companies, Singapore companies, U.S. companies, European companies
Once overseas entities have completed their procurement, sales, and settlement, a new issue arises:
For the same profit, in which country or region should taxes be paid?
If a company is taxed overseas and, at the same time, Chinese tax authorities tax the same income in accordance with relevant regulations, this may result in double taxation.
In such cases, eligible Chinese residents (citizens) may apply to initiate the process in accordance with the tax treaty and relevant procedures.Mutual Agreement Procedure (MAP)The
According to the procedures currently published by the tax authorities, if a Chinese resident believes that tax measures taken by a contracting party have resulted in, or will result in, taxation that does not comply with the provisions of a tax treaty, the resident may file an application with the provincial-level tax authority, requesting that the State Taxation Administration resolve the matter through the mutual agreement procedure with the competent authority of the other party. (Zhejiang Provincial Tax Bureau)
At the same time, starting in 2025, the rules governing the “Certificate of Chinese Tax Residency” have been revised; businesses or individuals may now apply for a tax residency certificate for any calendar year in which they qualify as Chinese tax residents. (Shanghai Municipal Taxation Bureau)
This is particularly noteworthy for cross-border enterprises that adopt a “purchasing from overseas + selling overseas + multi-party settlement” structure.
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10.The six business chains that truly need to be overhauled are these
If you're currently involved in cross-border e-commerce, I suggest you don't just ask:
“Have I paid my taxes?”
Instead, it checks the following six chains one by one:
① Goods Flow
Purchasing → Receiving → Shipping → Customs Clearance → Overseas Warehouse → Final Sale
② Order Flow
Platform Order → Shipment → Delivery Confirmation → Refund → After-Sales Service
Domestic Value-Added Tax → Corporate Income Tax → Export Tax Rebates → Overseas Tax Filing → Withholding and Filing for Cross-Border Payments
Ultimately, the goal is to:
A transaction can be tracked from the order all the way through customs clearance, logistics, payment collection, and tax filing.
11.Sellers operating multiple stores or under multiple business entities should prioritize “business consolidation”
For cross-border businesses operating multiple stores or companies, we recommend prioritizing the establishment of a system that:
“The relationship between ”merchant—store—platform—warehouse—logistics—order—customs declaration.”
Example:
sports event
Mapping required
Domestic Companies
Which stores/platforms?
store
Which seller?
Products
Which procuring entity?
declare at customs
Who acts as the exporter?
overseas warehouse
Under which company's name?
logistic
Which business entity is responsible?
payback
Which account will be charged?
tax rebate or refund
Which company is filing the report?
(manufacturing, production etc) costs
How to Allocate Costs
In particular, among affiliated companies within the group, it is not recommended to routinely engage in the following practices for the sake of “convenience”:
Company A handles procurement, Company B handles customs clearance, Company C handles collections, and Company D handles tax refunds.
However, there are situations where contracts, invoices, and actual business operations simply cannot explain the circumstances.
12.7 Compliance Tips for Cross-Border Sellers
01｜Reviewing Overseas Payments
Review the overseas payments made over the past 12 months or even longer, and assess each transaction individually:
For these and other patterns, you need to plan ahead:
Contracts, pricing, funding, profits, tax residency, and the chain of evidence for related-party transactions.
07｜Don’t complicate your business operations just to “pay less tax”
A truly sound cross-border tax and financial structure should be:
The business transactions are genuine, the parties involved match, the prices are reasonable, the funding sources are transparent, the supporting documents are complete, and the tax treatment is justifiable.
Scan the QR code to add our online customer service representativeWeChat ID: kuajinghg001, GetCustomized Cross-Border Compliance Solutions, where professional consultants will provide one-on-one analysis of your business structure to identify the compliance path that best suits your needs.
Note: This article addresses matters such as cross-border payments, withholding tax for non-resident enterprises, export tax rebates (or exemptions), and tax treaty benefits. Actual application must be determined based on the nature of the transaction, the parties’ status, the contract, and the substance of the business; specific provisions are subject to the relevant tax authorities and currently effective policies.
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