“The tax authorities are here. What should I do?”

The first reaction of most cross-border sellers is panic—they don’t know what to do, what to provide, whether they can refuse, or if refusing will cause even more trouble.

But what you may not know is:According to Announcement No. 10 of the State Taxation Administration in 2026, tax audit documents have been completely revised, and enterprises now have clear rights to ensure compliance and protect their interests when facing tax audits.

This article isn't about ”how to get caught,” but ratherWhen Can You Say No?The

I. Tax Audit Documents Have Been Updated—What Changes Lie Behind This?

Starting in 2026, tax authorities nationwide will uniformly adopt a new version of audit documents. There are three key changes:

The essence of renewal is:Tax audits have shifted from ”auditing everything” to ”inspections in accordance with regulations,” and companies’ legal rights to protection have been clarified.

II. In which three situations can you refuse in accordance with the law?

Scenario 1: Tax documents were not served in accordance with the law

When tax authorities conduct an audit,Valid tax documents must be served on the party being audited.(such as a “Tax Audit Notice”), and the document must specify details such as the scope of the audit, the identification information of the auditors, and the timeframe for the audit.

If the inspector:

No written documents were presented; only a verbal notification was given.

The document lacks required legal elements (e.g., the inspection items are not specified)

The issuing authority of the document differs from the agency that actually conducted the on-site inspection

You have the right to request that the document be corrected or to withhold cooperation until the document is served in accordance with the law.

Scenario 2: The scope of the inspection exceeds the matters specified in the document

The new version of the audit documents requires that the items to be inspected be clearly listed. This means that auditorsInspections may only be conducted with respect to the specific matters set forth in the documents., and the scope should not be expanded arbitrarily.

Common examples of examinations that exceed the scope of practice include:

The document states that it is reviewing ”VAT filing status,” yet it requests all bank statements.

The document states that it is an audit of ”2024 income tax,” yet it reviews accounts from before 2021.

Requests for screenshots of internal systems and cross-platform data not listed in the documentation

If you encounter a request that goes beyond the scope of the inspection, you may clearly state: “This matter is not within the scope of this inspection. Please provide supplementary documentation or apply for a new inspection authorization.”

Scenario 3: Inspections Conducted in Violation of Statutory Procedures

Tax audits are subject to specific procedural requirements. The following situations constitute non-compliance, and businesses have the right to refuse to cooperate and to file a complaint:

Unannounced On-Site Inspections(The standard procedure is to first serve the notice, giving the company time to prepare.)

Exceeding the statutory inspection deadline(The tax audit notice specifies a deadline; if the case is not resolved by that date, a new notice must be issued.)

Request for Information Not Related to Taxes(e.g., if you are asked to provide information such as shareholders' personal bank accounts or family members' information)

Forced inspections outside of working hours(No inspections are permitted at night or on holidays unless there is an emergency.)

Please feel free to contact me if you need anything.Cell phone: 18676749275 ｜ WeChat: qcygscszk

III. Before Saying ”No,” Follow These 4 Steps

It’s your right to say no, but how you say it matters.It’s not about stubbornly resisting, but about responding in accordance with the rules.

Step 1: Verify the Documents

Ask the inspectors to present the tax audit notice and their law enforcement credentials, and carefully verify that all required information is complete and that the scope of the audit is clearly defined.

Step 2: Document and Retain Evidence

Keep a written record of the entire inspection process, including the names of the inspectors, their ID numbers, the time of arrival, and a list of the documents requested. If necessary, the entire process may be audio-recorded (a legal right).

Step 3: Submit written comments

If you believe there are procedural issues with the inspection, you may submit a written statement of defense while cooperating with the inspection; this right is clearly stated in the updated documentation.

Step 4: File an Administrative Review

If you believe that an administrative action taken by the tax authorities has infringed upon the legitimate rights and interests of your company, you may file an application for administrative reconsideration with the higher-level tax authorities within 60 days.

IV. Proactive Compliance Is the Best Way to ”Say No”

The right to say ”no” is important, but what’s even more important is:Make sure there are no issues that could be investigated.

The tax risks faced by cross-border e-commerce sellers are primarily concentrated in the following areas:

Whether a tax audit is justified depends on whether there are any issues with your books. Clear records, proper tax filings, and complete documentation are your strongest defense.

V. Qicaiying: Experts in Cross-Border Financial and Tax Compliance

Qicaiying Group has specialized in cross-border e-commerce financial and tax compliance for over 10 years, offering:

✅ Tax Risk Assessment: Compare platform data with reported data to identify potential risks arising from discrepancies

✅ Accounts Review and Correction: Assist companies in organizing historical accounts and standardizing financial records

✅ Tax Filing Services: Comprehensive coverage of Value-Added Tax, Corporate Income Tax, and Individual Income Tax

✅ Audit Response Support: Provide professional tax specialists to accompany you during tax audits and assist in preparing written statements

Free Tax Risk Assessment

Want to know if your current tax filing data is at risk of being audited?

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Under ”Tax Diagnosis,” Qicaiying Consultants will provide you withComparison and Analysis of Reported Data, identify risk areas, and propose corrective measures.

About Enterprise Caiying Group

Established in 2015 and headquartered in Shenzhen, Qicaiying Group specializes in providing one-stop financial, tax, and corporate compliance services to cross-border e-commerce companies and businesses expanding overseas. Its services include Hong Kong and overseas company registration, bank account opening, cross-border financial and tax compliance, VAT and EPR registration, bookkeeping services, and corporate identity planning. Having served over 10,000 companies to date, it is a trusted financial and tax compliance partner for cross-border sellers.

Qicaiying Group provides business, commercial, and tax services related to the registration of foreign companies, including U.S. companies, Singaporean companies, Japanese companies, Thai companies, Malaysian companies, Canadian companies, Mexican companies, Brazilian companies, UK companies, French companies, New Zealand companies, Vietnamese companies, Indonesian companies, Philippine companies, and Dubai companies, among others. We also provide corporate services for domestic company registrations in Hong Kong, Shenzhen, Guangzhou, Shanghai, Hangzhou, Beijing, and Hainan, including annual reviews and audits, bookkeeping and tax filing, Mandatory Provident Fund (MPF) contributions, information updates, bank account openings, ODI filings, BVI registrations, tax compliance, and cross-border e-commerce support and management services.

Please feel free to contact me if you need anything.Cell phone: 18676749275 ｜ WeChat: qcygscszk