There is no shortage of policy incentives, but few sellers truly understand that behind these incentives lies a corresponding upgrade in authenticity verification.

I. A Single Advance Tax Refund Triggers a Retrospective Audit

At the end of 2025, a cross-border e-commerce company with annual sales exceeding 100 million exported a batch of home furnishings to an overseas warehouse in the United States via the 9810 model, with a declared customs value of 10 million yuan and a tax refund rate of 13%. Under the ”tax refund upon departure” policy, a preliminary tax refund of 1.3 million yuan was credited to the company’s account within four business days—a clearly visible improvement in capital efficiency compared to the three- to six-month reimbursement cycle under the traditional model.

But the problem lies in the subsequent liquidation process.

To speed up cash flow, the company included the estimated retail price—rather than the cost price—in its customs declaration, resulting in a discrepancy between the customs data, the purchase invoices, and the bank payment amounts. During the annual settlement, the tax authorities, based on cross-checks conducted under the Golden Tax Phase IV system, determined that the company’s requested tax refund lacked support from genuine business transactions. They required the company to pay the difference in taxes and initiated a special audit of the non-compliant portions of its tax returns.

9810 has indeed accelerated cash flow, but it has not simplified compliance requirements. On the contrary, the prerequisite for “tax refund upon departure” is that data preparation prior to departure is sufficiently thorough. 

II. The Three Major Structural Benefits Brought by 9810

The 9810 model (cross-border e-commerce export to overseas warehouses) will see three key policy benefits in 2026:

● Tax refunds upon departure, accelerating cash flow by 90% or more

You can apply for an advance tax refund as soon as the goods have cleared customs for export, without having to wait for the overseas sale to be completed. Based on an export value of 10 million yuan and a tax refund rate of 13%, an advance tax refund of 1.3 million yuan can be credited to your account within 3 to 5 business days, whereas the traditional process takes 3 to 6 months.

● Cancel the overseas warehouse registration; the business restructuring takes effect immediately

According to Announcement No. 167 of 2024 issued by the General Administration of Customs, the 9810 model no longer requires advance registration of overseas warehouses; customs declaration can now be completed simply by uploading electronic booking data, significantly reducing the time required.

● The duty-free policy for returned goods has been extended through the end of 2027

From January 1, 2026, through December 31, 2027, cross-border e-commerce goods that are returned to China in their original condition within six months of the date of export due to slow sales or returns shall be exempt from import duties, value-added tax, and consumption tax levied at the time of import.

 Not sure if your 9810 customs declaration data is compliant?

Cell phone: 18676749275 ｜ WeChat: qcygscszk, text 【9810 Assessment】 to receive a free compliance assessment.

III. Six Compliance Pitfalls That Cannot Be Ignored

The flip side of these benefits is that tax authorities are simultaneously tightening their verification of the authenticity of claims. Any lapse in any of the following six areas could result in the recovery of advance tax refunds or even trigger a special audit:

● Inconsistent criteria for determining the customs declaration value

The customs value should be calculated as the purchase cost plus domestic freight and handling charges plus a reasonable profit margin; it is strictly prohibited to declare the value based solely on the platform’s selling price. Since there is no uniform national standard, you must confirm the criteria with the competent tax authority in advance.

● Challenges in Issuing Export Invoices

The 9810 system is essentially a B2C model; in theory, it requires issuing invoices on a transaction-by-transaction basis to a vast number of end consumers, but this is impractical in reality. Most regions allow for consolidated invoicing or temporary exemption from invoicing, but prior registration and confirmation with the local tax authority are required.

● Mismatch between the entity receiving foreign exchange and the entity operating multiple stores

The platform store owner, the customs declarant, and the foreign exchange recipient must all be the same entity. If proceeds are diverted through a personal account, this will result in the immediate suspension of tax refund eligibility.

● Tax-deductibility of overseas expenses is subject to restrictions

There are statutory deduction limits for overseas commissions and advertising fees (5% for commissions and 15% for advertising fees), and the acceptance rate for overseas supporting documents is low. You must retain the ”three-in-one” set of documents: contract, settlement statement, and payment voucher.

● Three sets of revenue recognition standards are applied in parallel

For accounting purposes, ”goods shipped” do not constitute revenue recognition; for corporate income tax purposes, revenue is recognized based on actual sales; and for value-added tax purposes, a preliminary tax refund must be claimed in the month of export. Since these three sets of standards are inconsistent, accounting and tax reporting must be handled separately.

● Following the 9810 process ≠ automatic compliance

Tax authorities do not audit the tax returns themselves, but rather the authenticity of business operations—specifically, whether the flow of goods, sales, funds, and supporting documentation form a complete cycle. Without the support of a professional finance and tax team and the necessary systems, blindly initiating the 9810 process is highly likely to trigger an audit.

📌 If you are already experiencing any of the issues mentioned above, we recommend taking immediate corrective action to ensure compliance.
Cell phone: 18676749275 ｜ WeChat: qcygscszk(math.) genus

IV. Key Points of the Full 9810 Compliance Process

From deployment to winding down, the 9810 compliance process can be broken down into four key steps:

1. Preliminary Qualification Filing (1–3 days)

Complete customs registration, obtain the e-Port card, complete foreign exchange registration, and register for export tax refunds (or exemptions); prepare the overseas warehouse cooperation agreement and booking confirmation for reference.

2. Export Customs Clearance

Enter ”9810” for the supervision method, ”HWC-YT (Overseas Warehouse Pre-Refund)” for the tax refund (exemption) transaction type, and include the following key documents: the tax refund copy of the customs declaration form, the credit copy of the special VAT invoice, and the first-leg logistics bill of lading.

3. Pre-tax refund application (funds will be credited within 3–5 days after departure)

When submitting a preliminary tax refund application through the Electronic Tax Bureau, you must clearly distinguish between the ”sold” and ”unsold” portions; if no distinction is made, the entire amount will be treated as unsold.

4. Annual Settlement (by April 30 of the following year)

Match actual sales to the customs declaration numbers; confirm the final tax refund amount for sold items, and for unsold or slow-moving items, either repay the refunded tax or carry it forward to offset future periods. Submit the “Preliminary Tax Refund Settlement Statement” along with sales details and payment receipts.

Five Key Areas of Audit Focus: Accuracy of the declared customs value, proof of control over overseas warehouses, completeness of foreign exchange receipts, a closed-loop chain of documentation, and reasonableness of the sales turnover rate. None of these can be overlooked.

If you’d like to learn how to set up a 9810-compliant structure through a Hong Kong company, please feel free to contact Qicaiying.
Cell phone: 18676749275 ｜ WeChat: qcygscszkThe

V. Establishing a Compliance Framework Upfront: Why Hong Kong Companies Are a Key Piece of the 9810 Puzzle

The 9810 model imposes strict ”three-stream consistency” requirements on foreign exchange receipts, document management, and tax filings. Incorporating a Hong Kong company into a cross-border business structure can enhance compliance efficiency in three ways:

First, centralize the entity receiving foreign exchange. By consolidating payments from multiple platforms into a Hong Kong company’s corporate bank account, you can avoid the risk of losing tax refund eligibility caused by funds being diverted to personal accounts.

Second, the chain of documentation is complete. Hong Kong companies have independent auditing and accounting systems and can issue standardized business settlement and expense documents that meet the ”five-in-one” requirement for the 9810 customs clearance process.

Third, optimizing the tax burden structure. Make reasonable use of the combined advantages of Hong Kong’s territorial source principle for profits tax and the Mainland’s export tax rebate policy.

VI. Qi Cai Ying: End-to-End Services from Structural Setup to Tax Refund Implementation

Established in 2015, Qicaiying specializes in serving cross-border e-commerce sellers and companies expanding overseas, offering integrated solutions that include Hong Kong company registration, bank account opening, cross-border financial and tax compliance, and guidance on the 9810 tax refund process.

● Hong Kong Company Registration + Bank Account Opening—Through major banks such as HSBC, Overseas-Chinese Banking Corporation, and Dah Sing Bank, ensuring proper setup of the entity for receiving foreign currency.

● Comprehensive Guidance on the 9810 Tax Refund Process—From qualification registration and customs declaration to annual settlement, we provide compliance solutions ensuring ”consistency of the three flows” and support in aligning with tax authority requirements.

● Establishing a Cross-Border E-Commerce Financial and Tax Compliance System—An integrated financial and tax solution for businesses that covers cross-checking of sales data, bank statements, and customs declaration documents, as well as document management.