Mr. Wu, an Amazon seller in Shenzhen, had been hesitant to apply for a tax refund after shipping his goods to an overseas warehouse—“How can I get a tax refund if the goods haven’t been sold yet?” He followed the old practice of waiting until the sales were completed, but as a result, his funds were tied up in the overseas warehouse for more than half a year, causing severe cash flow problems.

He didn’t know that the new regulations issued by the State Taxation Administration at the end of 2025 had already been implemented in many places in 2026: for goods in overseas warehouses (9810), “tax refunds are issued upon departure, with sales accounted for later”—meaning that once goods are cleared through customs and leave the country, a tax refund can be obtained immediately, without having to wait for them to be sold.

This article provides a comprehensive overview of the policies, procedures, and registration requirements for export tax rebates under Form 9810. If you operate an overseas warehouse, we recommend bookmarking this page.

01

9810 isn't just about tax exemptions

Many sellers mistakenly believe that 9810 (cross-border e-commerce export to overseas warehouses) is limited to tax-exempt transactions. This is incorrect. 9810 is a customs supervision code, not the name of a tax policy. If the conditions for export tax refunds (or exemptions) are met, a tax refund claim may be filed in accordance with regulations; if the conditions for tax exemption are met, a tax exemption declaration should be filed. These two procedures must not be confused.

Prerequisites for Tax Rebates: Completion of export tax rebate (or exemption) filing; goods falling within the scope of tax rebates (or exemptions); possession of compliant purchase documentation; and complete records of export sales, foreign exchange receipts, and financial accounting. Manufacturing enterprises must file under the “exemption, credit, and refund” system, while foreign trade enterprises must file under the “exemption and refund” system.

Important Reminder: For export transactions eligible for VAT refunds or exemptions, special VAT invoices must not be issued. If compliant purchase documentation has not been obtained, a separate determination must be made as to whether the transaction qualifies for an exemption; it cannot be directly treated as exempt.

02

New Policy on Tax Refunds Upon Departure

Pursuant to the “Announcement of the State Taxation Administration on Matters Concerning Support for the Development of Cross-Border E-Commerce Export Overseas Warehouses and Export Tax Refunds (Exemptions)” (No. 3 of 2025), applications for export tax refunds (exemptions) for 9810 goods may be filed immediately after customs clearance for export, without having to wait for the overseas sale to be completed.

There are two specific procedures: For goods that have already been sold, file for a normal tax refund in accordance with current regulations; for goods that have not yet been sold, follow the “tax refund upon departure, with final settlement upon sale” approach—first apply for a provisional refund (export tax refund) based on customs declaration forms and other supporting documents, and settle the final amount later. Under the old model, businesses had to wait until sales were completed, tying up funds for 3–6 months; under the new model, the timing of tax refunds has been significantly brought forward.

By 2026, the initiative had been implemented in multiple locations, including Wuhan, Chongqing, and Dalian: Dalian facilitated the first overseas warehouse advance tax refund; as of June 2026, the cumulative amount of advance tax refunds processed exceeded 4 million yuan, and the policy benefits are now translating into cash flow for businesses.

If you’re facing a similar situation—operating an overseas warehouse for Amazon or an independent e-commerce site, unsure how to file for the 9810 “tax refund upon departure” declaration, or worried you won’t be able to claim your tax refund—feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat/Phone: 18620388671). We’ll help you with tax refund registration and filing planning. Feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat/Phone: 18620388671), and we’ll help you sort out this entire process from start to finish.

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03

How to File for a Pre-Tax Refund

To apply for an advance export tax refund, use the customs declaration form with customs supervision code 9810 and enter “Overseas Warehouse Advance Refund” (code HWC-YT) in the “Tax Refund (Exemption) Transaction Type” field. A distinction must be made between unsold and sold goods: if no distinction is made, all goods will be treated as unsold, and an advance tax refund must be claimed for the entire shipment.

Manufacturing enterprises shall use a separate declaration number, while foreign trade enterprises shall use a separate association number. For enterprises that have filed for an advance tax refund, during the settlement period (from the 1st day of the month following the month in which the tax authority finalizes the advance tax refund through April 30 of the following year), settlement shall be processed in accordance with the VAT filing period, with overpayments refunded and underpayments collected.

Document Filing: In addition to standard filing documents, if an export contract cannot be obtained, supporting documents such as overseas warehouse booking slips, ownership documents for self-operated overseas warehouses, or lease agreements may be used. Keep all documentation on file to ensure a smooth accounting process later on.

04

9610 and Income Tax Incentives

Small and medium-sized sellers engaged in cross-border e-commerce retail exports (9610): Those who have obtained valid input vouchers may use the “list-based release and consolidated declaration” method to file a customs declaration for a tax refund; those who have not obtained vouchers but meet the eligibility criteria may apply for VAT and consumption tax exemptions in accordance with Cai Shui [2018] No. 103 (Trial) (Tax-exemption management has been implemented on the Comprehensive Pilot Zone’s online platform).

Corporate Income Tax: According to Announcement No. 36 of 2019, eligible cross-border e-commerce enterprises will be subject to a trial fixed-rate tax assessment, with a uniform taxable income rate of 4%; those meeting the criteria for small and low-profit enterprises are eligible for preferential treatment. This represents a substantial tax relief for small and medium-sized sellers who lack complete accounting records and supporting documents.

Many regions have implemented “paperless, no-filing, and contactless” reforms, reducing the tax refund processing time for Category I and II export enterprises with high credit ratings to within three business days. The simpler the process, the faster the cash flow.

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05

How to Get a Tax Refund

First, file for registration: Before filing your first tax refund claim, complete the registration for export tax refunds (or exemptions) and gather all purchase documents. Second, file claims based on status: File for a standard refund for goods that have been sold, and file for a preliminary refund (marked HWC-YT) for goods that have not been sold; do not mix the two.

Third, retain documentation: Keep a complete set of documents on file—including customs declarations, booking confirmations, lease agreements, and foreign exchange receipts—to ensure consistency among the four flows. Fourth, reconcile the general ledger: Compare tax refunds with tax exemptions; claim refunds where possible, and apply exemptions where eligibility criteria aren’t met—avoid the loss that comes from a blanket exemption approach.

In a nutshell: The key change to the 9810 export tax rebate policy in 2026 is that “tax rebates are available as soon as the goods leave the country.” By moving the timing of the tax rebate from after the sale to after the goods leave the country, the financial pressure associated with stocking overseas warehouses is directly alleviated.

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