If you’ve been shipping goods via the “buy-and-ship” export method over the past few years, please read this article carefully from start to finish.

I’m not saying this to scare you, but the regulatory environment in 2026 has undergone a fundamental shift—practices that used to slip through the cracks no longer do. The tax authority’s latest stance is very clear: export transactions involving purchase orders without proper customs declarations or input invoices will be directly treated as domestic sales, and VAT will be retroactively levied at a rate of 13%. There’s no room for negotiation, no exceptions, and no ”we’ll let this one slide this time, but be careful next time.”

01 What is “buy-side export,” and why was it allowed in the past?

Simply put: You sourced your goods domestically and shipped them from China, but you didn’t file the customs declaration under your own name—you purchased someone else’s customs declaration (a “purchased declaration”) and shipped the goods under that person’s name.

It used to be possible because the data between the tax authorities and customs wasn’t fully integrated. The three sets of data—how much your platform sold, how much was shipped, and how much was declared for customs—were all separate, so the tax authorities couldn’t see the full picture.

But by 2026, all three data sets had been integrated.

02 Three Changes in 2026 That Will Make Paying the Bill Completely Unfeasible

Change 1: Full Push of Platform Data

Starting in October 2025, Amazon began submitting sellers’ sales data to the Chinese tax authorities for the first time. Shortly thereafter, following a fine, Pinduoduo also began submitting its full sales data. Now, for any store registered with a domestic business license, every sale made on the platform is accurately reported to the tax authorities’ system on a quarterly basis.

Just think about it: if you’ve sold 50 million worth of goods on the platform but there isn’t a single record under your name in the customs declaration system—this discrepancy in the data doesn’t even require a manual check; the system automatically flags it as a warning.

Change 2: Real-time Integration of Customs and Tax Systems

Now, whenever you file an export customs declaration, the data is synchronized with the tax authorities the very next day. Whether your exports are compliant, whether ownership of the goods is clear, and whether the declared value matches the platform data—it’s all clear at a glance.

In the past, the ”security” of export invoicing was based on information silos. Now, the Golden Tax Phase IV initiative has eliminated those silos.

Change 3: Enforcement of the "deemed domestic sales" policy has been comprehensively strengthened

In the past, the rule regarding ”tax adjustments for transactions treated as domestic sales” was often merely theoretical. Enforcement was lax, interpretations varied from region to region, and cases involving small amounts were generally ignored.

After the Value-Added Tax Law officially takes effect in 2026, this rule will shift from ”application on a case-by-case basis” to ”a one-size-fits-all approach.” As long as there are no formal customs declaration records or input invoices, VAT must be paid directly at a rate of 13%—not 13% of profit, but 13% of turnover.

Here’s a concrete example: If your annual sales are 10 million, and they’re deemed to be domestic sales, the back taxes you’ll owe amount to 1.3 million—and that doesn’t even include late payment penalties or fines.

Not sure how much risk your payment process entails? Scan the QR code to add a Qicaiying consultant and get a risk assessment so you can clearly see where you stand.

Cell phone: 18676749275 ｜ WeChat: qcygscszk

03 I’ve Already Been Investigated—How Should I Respond?

❌ Mistake #1: Deleting data and closing the store

The tax authority’s data comes from platform reports, not from what you provide yourself. Deleting the records only removes them from your phone; the logs in the tax authority’s system remain completely intact. Closing your store won’t help either—the historical data has already been documented.

❌ Mistake #2: Using connections or asking for favors

Data comparisons are performed automatically by the system, and alerts are flagged automatically by the system. It’s not a matter of whether the administrator wants to investigate your issue; rather, the system has already pushed the list of anomalies to the administrator’s to-do list. If the administrator doesn’t handle your case, their supervisor will hold them accountable.

✔️ The Right Way to Do It: A Three-Step Approach

Step 1: Immediately organize all historical data—platform sales figures, customs declaration records, purchase documents, and payment receipts—and compile a comprehensive list of everything. Get a clear picture of your actual financial situation.

Step 2: Proactively contact the tax authorities and file a corrected return before a case is officially opened. The severity of penalties differs significantly between voluntarily filing a corrected return and being audited.

Step 3: Seek assistance from a professional firm. Their role is not to ”smooth things over” for you, but to help you explain your business model using professional terminology in order to secure the lowest possible back taxes and the least stringent corrective measures.

The cost of saying the wrong thing could be dozens of times higher than the fee you’d pay a professional consultant.

04 The most important question: Now that we’ve paid for the export, what happens next?

The answer to this question isn’t ”how to keep getting by,” but ”how to go legit.”

Compliance does not mean shutting down all your stores and starting over. Compliance means helping you establish an export structure recognized by the tax authorities—including a unified entity for centralized customs declaration, a chain of evidence demonstrating the alignment of the four flows (goods, funds, documents, and information), and proper customs clearance via the 9810 or 0110 procedures—thereby eliminating the risk of being treated as domestic sales at the source.

Once the framework is in place, you should open your store, ship your orders, and scale up your operations—with every shipment processed as a legitimate export. This isn’t ”increasing costs”; it’s ”defusing a ticking time bomb.”

05 Why Choose Qicaiying to Manage Compliance Risks?

Being summoned for a meeting by the tax authorities or receiving a risk control notice isn’t something that can be resolved simply by finding someone who ”knows about taxes.” What you need is a team that has handled this countless times—one that knows exactly what the tax inspector will ask, what responses will be accepted, and what statements could be used as grounds for a tax assessment.

🔹 A professional team of nearly 400 people, handling tens of thousands of compliance cases annuallycase (law)

Qicaiying is composed of seasoned certified public accountants, tax practitioners, and cross-border tax and finance consultants. The firm holds three TCSP-licensed secretary licenses and operates its own Hong Kong accounting firm. We are not a makeshift consulting firm, but a professional organization with deep, long-term expertise in cross-border tax and financial compliance. When faced with inquiries, written investigations, or interviews from the tax authorities, we’ll be there to help you respond using professional language recognized by the tax authorities—rather than leaving you to handle it alone.

🔹 We don’t just provide solutions—we work with you on a project basis to ensure full compliance and successful implementation

Many firms simply hand over a report and call it a day. At Qicaiying, we provide end-to-end project-based support: on-site due diligence to assess your actual financial situation → customized solutions → assistance with sorting out past accounts and completing the chain of evidence → full support during tax communications. A dedicated specialist follows up on every step—you won’t have to handle this alone.

🔹 Support Throughout the Entire Process—It’s Not Just About Solving This One Issue

Once the crisis has been resolved, establishing a compliance framework is the key. Qicaiying provides full-lifecycle support for cross-border finance and taxation: from resolving historical issues and facilitating applications for assessed taxation to establishing a formal export structure, managing annual filings, and securing tax refunds—let this crisis serve as the starting point for your complete transition to compliance, so there will never be a next time.

When it comes to compliance, the biggest risk isn’t being late—it’s trying to handle everything on your own. Finding the right team is key to avoiding detours when it matters most.

Not sure how much risk your payment process entails? Scan the QR code to add a Qicaiying consultant and get a risk assessment so you can clearly see where you stand.

Cell phone: 18676749275 ｜ WeChat: qcygscszk

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 company registration in Hong Kong and overseas, bank account opening, cross-border financial and tax compliance, VAT/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 registration and related commercial and tax services for companies in the United States, Singapore, Japan, Thailand, Malaysia, Canada, Mexico, Brazil, 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 assistance. 📱 Mobile: 13045886252, 💬 WeChat: qcy20251218