跨境电商财税合规指南:9810 模式之外,两大模式适配 5000 万体量卖家
发布时间:2026-03-05

Recently, a lot of Amazon sellers who stock their overseas warehouses have been complaining:

"9810 sounds compliant, but it's too complicated to operate, there are a ton of documentation requirements, and we're doing tens of millions of dollars a year, so is it really necessary to go through all that trouble?"

This question was also sharply thrown out by a seller in the furniture category - Mr. Zhou - during an exchange we had in Hangzhou last week.

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Here's the situation with Mr. Chow:

Annual sales of more than 30 million, all the goods directly sent to the U.S. FBA warehouse. Before has been "buy single export", now want to formalize, but a study of 9810, the head is big: and data docking, and tax returns, the process is cumbersome and prone to error.

He said:"I just want to simply ship my freight and get my money back safely. Is there a simpler path to compliance besides 9810?"

In fact, Mr. Zhou's confusion is very representative.For small and medium-sized sellers with annual sales of less than $50 million, there are two more flexible and grounded alternatives if they find 9810 too heavy and complex.

The point is:Where is your money? Where do you want it to end up?

In today's post, we're going to break down these two alternative paths and share an actionable Security Transition Program. Be sure to read to the end for exclusive compliance counseling benefits to help you take the easy way out. You can also add our online customer service(WeChat: jxhqcy890 / Mobile: 16625410105)Arrange professional consultants to answer questions, provide professional advice and one-on-one service throughout the process.

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01.The essence of 9810 is to tie three things together to do

First of all, let me explain: 9810 (Customs Supervision Code) is the supervision mode specially for "cross-border e-commerce export overseas warehouse", which is essentially to bind "cargo flow + capital flow + data flow" and make a unified declaration.

It's like buying a branded computer, the whole machine is good but when you take it apart, the motherboard, CPU and memory sticks are all separate. For some sellers, "the whole machine is too expensive and too difficult to repair", so can you match them as needed?

The answer is: yes you can!

In view of the complexity of the 9810, there are two more flexible disassembly solutions to solve the "goods" and "money" problems respectively.

如果你也被类似的合规问题困扰,不妨留言和我们聊聊,让专业的人帮你少走弯路。有跨境电商账务处理、税务申报、证据链整理、进出口权备案与退税、香港公司架构搭建框架等业务咨询也可添加我司在线客服(WeChat: jxhqcy890 / Mobile: 16625410105)Arrange professional consultants to answer questions, provide professional advice and one-on-one service throughout the process.

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02.Alternative I: 0110 In-country Direct Collection

Suitable for the "money can go home"

ralph lauren core logic:

Customs clearance for export is done using traditional general trade (0110) methods, while ensuring that all sales returns are returned to the domestic company account in a compliant manner through the public channel.

ralph lauren polo real cases:

Mr. Zhou from Dongguan, whom we have served, is taking this path. He is a furniture seller doing Amazon US station, the upstream supply chain is stable, and he can issue formal invoices.

Through the use of licensed third-party payment institutions such as MilesHub, he withdraws the platform's dollar returns directly to his domestic company's dollar account, each with a compliant foreign exchange water bill and settlement voucher.

In terms of customs declaration, he used 0110 to declare normal shipments. As the main body of customs declaration and the main body of payment is the same company, it realizes the "goods and money are the same" and is clean.

ralph lauren polo ralph lauren outlet for people:

  • All amounts have been/can be recovered through the company's public account;
  • Able to provide input invoices and willing to do export refunds;
  • Do not wish to engage in complex cross-border structures.

⚠️ Risk Warning: Do not "separate goods from money"!

Customs declaration is company A, but the money into the company B or personal account, in the Golden Tax IV system at a glance, it is very easy to trigger the tax warning, not only can not refund the tax, but also may be "regarded as domestic sales" to recover the 13% value-added tax.

如果你也被类似的合规问题困扰,不妨留言和我们聊聊,让专业的人帮你少走弯路。有跨境电商账务处理、税务申报、证据链整理、进出口权备案与退税、香港公司架构搭建框架等业务咨询也可添加我司在线客服(WeChat: jxhqcy890 / Mobile: 16625410105)Arrange professional consultants to answer questions, provide professional advice and one-on-one service throughout the process.

03.Alternative 2: 0110 + Hong Kong Company Structure

Suitable for "money already outside the country".

ralph lauren core logic:

Accept the reality that the funds are stranded outside the country and use a Hong Kong company with commercial substance to take over the funds, while the domestic company focuses on making compliant supplies and customs declarations.

ralph lauren polo real cases:

Mr. Li from Shenzhen, who has been using his family's account to collect Amazon payments before, has deposited millions of dollars overseas over the past few years.

We helped him to register a Hong Kong company and design the following structure:

The domestic company "sells" goods to the Hong Kong company according to 0110 (signing purchase and sales contract, invoicing), and the Hong Kong company then arranges to send the goods to the FBA, in this way, the overseas funds will be legally entered into the account of the Hong Kong company, and the domestic company with the export declaration and the contract, it can also declare the tax rebate smoothly.

ralph lauren polo ralph lauren outlet for people:

  • There is a large historical legacy and a large amount of money is already offshore;
  • Difficulty in transferring all returns back into the country;
  • Willingness to set up offshore structures, but need to ensure their "authenticity".

⚠️ Risk warning: Don't become a "shell company"!

A Hong Kong company cannot just be a "pass-through tool", but must have real operational behavior, such as signing contracts, retaining profits, bearing logistics or after-sales costs. Otherwise, it is easy to be recognized as "false structure" by the tax authorities of both places, which will lead to penetrating audit.

如果你也被类似的合规问题困扰,不妨留言和我们聊聊,让专业的人帮你少走弯路。有跨境电商账务处理、税务申报、证据链整理、进出口权备案与退税、香港公司架构搭建框架等业务咨询也可添加我司在线客服(WeChat: jxhqcy890 / Mobile: 16625410105)Arrange professional consultants to answer questions, provide professional advice and one-on-one service throughout the process.

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04.Four Steps to Compliance for Cross-Border Sellers

Regardless of which option you prefer, we do not recommend a "one size fits all" hard switch. We have honed a set of "phased implementation, steady progress" transition plan for several clients, the core idea is: 👉 new business new approach, old business old approach, with time for space.

📌 Step 1: Cut the old and the new and stop immediately

  • Open a new collection account (domestic company account or Hong Kong company account);
  • All new orders, all new shipment batches, all go through the new compliance path;
  • Objective: To block new risks.

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📌 Step 2: Dual-track operation to validate the process

  • Keep the original path while running a new process with a small number of SKUs or new stores;
  • Full-process recording of customs declaration, collection, logistics and tax refund nodes;
  • Objective: To measure feasibility and cost and to avoid moving forward blindly.

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📌 Step 3: Migration of Mains, Gradual Replacement

  • Stabilized categories are transferred in batches on a monthly basis (15~20% per migration);
  • Sort out historical data and proactively address legacy issues;
  • Goal: No impact on revenue, increase compliance ratio.

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📌 Step 4: Fully integrate and optimize the upgrade

  • Close the old channels and fully embrace the new system;
  • Optimize tax structure and capital efficiency with the help of compliance data;
  • Goal: Make "compliance" a business enabler, not a stumbling block.

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The most important thing to remember: what's right, is best!

The question is often asked: which way is better?

In fact, for sellers with annual sales of less than 50 million, there is no standard answer, only "suitable".

  • If you have a naturally smooth money trail and a clean business structure, then it's decisive 0110 Direct Collection is clean and efficient;
  • If you already have a large amount of offshore capital and heavy historical baggage, then consider the 0110 + Hong Kong company structure for a pragmatic solution.

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Don't just pursue the theoretical "perfect compliance", choose the program that allows you to sleep tonight and make money tomorrow, is the true wisdom.

The different paths affect not only the immediate operation, but also the operational security and fiscal health of the next 1-2 years. If you:

  • Not sure how to categorize the current state of your funds?
  • Not sure if you should take a Hong Kong company?
  • Worried about the switching process affecting pop links and cash flow?

Feel free to add us on WeChat for a free, personalized path assessment to help you get to shore with less hassle and stability.

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Compliance transition is better sooner rather than later, the earlier the layout, the lower the cost, the more stable the development.

📌 If your business is in one of the following stages:

  • [Start-up period] Annual revenue < 20 million: Worried about the impact of zero filing, private collection, and Golden Tax Phase IV?
  • [Development Period] Annual revenue 20 million-100 million: troubled by export tax rebates, multiple private accounts, financial chaos?
  • 【成熟期】年营收 > 1亿:思考股权设计、库存优化、上市准备?

We have the corresponding solutions and practical experience.

如果你也被类似的合规问题困扰,不妨留言和我们聊聊,让专业的人帮你少走弯路。有跨境电商账务处理、税务申报、证据链整理、进出口权备案与退税、香港公司架构搭建框架等业务咨询也可添加我司在线客服(WeChat: jxhqcy890 / Mobile: 16625410105)Arrange professional consultants to answer questions, provide professional advice and one-on-one service throughout the process.

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Cross-border e-commerce tax compliance pain points

1、 Two sets of accounts: the internal accounts are chaotic and lead to difficult assessment, while the external accounts are difficult to file tax returns due to tax evasion and tax evasion;

2. Low income from external accounts, difficulties in financing, investment, mergers and acquisitions and IPOs;

3, no ticket purchases, personal accounts in and out of large sums of money, suspected of money laundering, tax evasion boss sleepless nights;

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Compliant Overseas and Domestic Equity Structures for Cross-Border Enterprises

1、Build a good in-country structure, that is, tax-saving and compliance

2, must set up a Hong Kong company as well as good positioning

3、Use of Hong Kong company offshore tax exemption policy

4. How is the store company built?

5、Why do we need to do offshore investment filing?

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Cross-border e-commerce fiscal and capital rational planning

1. Normative design for procurement without and with tickets

2. Reasonable pricing of goods exported from Hong Kong companies to achieve both tax savings and compliance

3, the company structure flow, goods flow, financial flow, tax flow, capital flow, contract flow, bill flow reasonable planning management

4、 How to make cross-border e-commerce enterprises and bosses' income legal? How to plan for shareholders' dividends?

5. Need to share the cost of payroll for in-country employees

6、 Must do cross-border service tax-free record

You can find the answers to all these questions in this PDF.

If you haveHong Kong Company Registration, Bank Account Opening, Annual Audit, Tax Audit, ODI Filing and Tax Compliance等需求,👉也可添加我司在线客服(WeChat: jxhqcy890 / Mobile: 16625410105)Arrange professional consultants to answer questions, provide professional advice and one-on-one service throughout the process.

Tags:
  • 9810
  • export tax rebate
  • E-commerce compliance
  • e-commerce tax
  • cross-border e-commerce