Aqiang, who works in the 3C industry, has always relied on “purchasing export documents”—since he doesn’t have his own customs declaration account, he pays to use other companies’ documents to ship his goods overseas. In August 2026, a major scandal broke out within his circle in Shenzhen: a company was fined over 90 million for tax fraud involving the purchase of invoices and matching documents, and seven people were arrested.

That’s when he started to panic: since he’d been paying the bill every year, was he actually skirting the line? 2026 has been dubbed the “year of the strictest tax oversight,” with three major changes hitting at once: the abolition of assessed taxation, the rollout of the Golden Tax Phase IV system, and the EU’s elimination of the 150-euro tax-free allowance effective July 1.

This article thoroughly explains the risks, audit criteria, and compliance pathways associated with "buy-and-ship" exports. Cross-border sellers who still use this method are encouraged to read it.

01

What Exactly Is a Documentary Credit?

Document Purchase for Export: When a company lacks import/export rights or does not wish to clear customs under its own name, it purchases a set of documents (such as clearance forms and customs declaration forms) from a “customs brokerage firm” in the name of another company to ship the goods overseas. While this may seem “convenient” on the surface, it essentially involves using another party’s name, resulting in a mismatch between the goods, funds, and the entities listed on the documents.

The fundamental difference between this and “0110 General Trade” and “9810 Overseas Warehouse” is this: in compliant exports, the entity handling customs clearance, the entity receiving foreign exchange, and the entity claiming tax refunds are all the same, ensuring consistency in the three flows; whereas in “buy-and-ship” exports, the entity handling customs clearance and the entity receiving foreign exchange are two separate entities, making tax refunds completely out of the question.

In a nutshell: From the very beginning, “invoice-based exports” were never “compliant exports”; they were merely a gray-area convenience that existed during a period of lax regulation. In 2026, this loophole was systematically closed.

02

Why Will 2026 Be the Toughest Year?

Three major developments have coincided: First, the cross-border e-commerce sector has completely phased out the fixed-rate taxation system and switched to an audited accounting-based taxation system, eliminating the loophole that allowed businesses to get by with “fixed-tax” arrangements. Second, the “Golden Tax Phase IV” initiative has been fully implemented, integrating data from customs, tax authorities, and banks. Third, starting July 1, 2026, the EU will eliminate the 150-euro duty-free threshold, meaning even low-value packages will need to undergo formal customs declaration.

The data speaks for itself: In the first half of 2026, authorities in Shenzhen, Dongguan, and Guangzhou conducted inspections of more than 2,000 businesses involved in cross-border e-commerce; in August, Shenzhen announced another major case of export tax fraud, resulting in a fine of 90,000,660 yuan and the arrest of seven individuals.

Case Study: The tax evasion case involving Shenzhen Zhongxingwang and others, involving “purchasing invoices and allocating tax credits,” featured a one-stop operation combining the issuance of fraudulent invoices, the purchase of invoices, and the allocation of tax credits, resulting in a total fine and confiscation of 12.3055 million yuan. This is not an isolated incident; it sends a clear signal.

If you’re facing a similar situation—you’ve been using the “buy-and-pay” export method but want to switch to formal customs declaration, yet are worried that your tax refund might not go through—we can help you assess your business model and design a compliant 0110/9810 pathway. 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

Seven Dimensions to Focus on During Audits

1. Does the name on the customs declaration match the entity receiving the foreign exchange? 2. Is the HS code accurate (incorrect classification is a major problem area)? 3. Is there a discrepancy in the flow of funds (the recipient of foreign exchange ≠ the shipper)? 4. Are the invoices genuine (fictitious invoicing is a frequent occurrence)? 5. Do the logistics records match the documentation? 6. Are there any discrepancies between the export destination and the declaration? 7. Are there any irregularities in related-party transactions?

Tax authorities focus on the “alignment of the four flows”: contract flow, capital flow, invoice flow, and goods flow. In “buy-and-sell” exports, these four flows are inherently misaligned, and the more they are investigated, the more evident this becomes.

Reminder: Many sellers think, “I didn’t commit tax fraud—I just paid the invoice,” but the act of paying the invoice itself undermines the basis for export tax rebates. If something goes wrong with an upstream supplier, downstream businesses will be investigated as well.

04

How to Navigate the Compliance Process

First, handle customs clearance yourself: Register for import/export rights and use your own company name to process shipments under code 0110 (general trade) or 9810 (overseas warehouses), claiming any eligible tax refunds in accordance with the law. Second, take full advantage of the new 9810 policy: You can apply for a tax refund in advance as soon as the goods leave the country, which actually provides more stable cash flow.

Article 3: For purchases made without invoices, use the “deduction based on invoices” method or report them truthfully; do not try to cover them up by using receipts. Fourth, ensure consistency among the four flows: contracts, funds, invoices, and logistics must align, and keep complete supporting documentation.

Key Mindset: Compliant exporting isn’t about “increasing costs”; rather, it’s about turning the “risks avoided” in the past into “predictable taxes.” In the long run, being able to claim tax refunds, secure financing, and go public is what truly saves money.

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05

Is it still too late to fix this?

First, suspend purchasing orders: All new orders must be placed under our own name. Second, review past transactions: Go through the value of goods and tax amounts from past purchasing orders to assess our risk exposure.

Third, transition to compliant exports: obtain the necessary import/export licenses, partner with a legitimate customs broker, and re-establish the “four-flow” documentation. Fourth, proactively correct declarations when necessary—this is far more proactive than waiting to be audited.

In a nutshell: When it comes to cross-border exports in 2026, paying the bill is a high-risk move—one that should be avoided whenever possible. The sooner you bring your operations into compliance, the sooner you can stop worrying.

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