With the implementation of big data oversight under the Golden Tax Phase IV initiative and the successive issuance of Documents No. 15 and No. 17 by the State Taxation Administration, the cross-border e-commerce industry has entered an era of stringent financial and tax compliance regulations. Recently, the founder of Yishuitong appeared on Hugo Cross-Border’s live stream series “Cross-Border Compliance Night Talk” to provide an in-depth analysis of the core elements of current policies, industry pain points, and compliance pathways. This article will systematically outline the key points and practical guidelines for financial and tax compliance in cross-border e-commerce, drawing on the core content of that presentation.

01 Analysis of the Policy Context: The Key Impacts of Document No. 15 and Document No. 17

● Document No. 15: Breaking Down Barriers to Income Information; The End of the Zero-Declaration Era

Circular No. 15 issued by the State Taxation Administration is not specifically targeted at cross-border e-commerce but applies to all e-commerce platforms. However, Article 5 explicitly requires that overseas internet platforms report information on stores registered by Chinese companies to the State Taxation Administration. This regulation has completely changed the previous situation in which tax authorities were unable to obtain revenue data from cross-border e-commerce stores.

Prior to this, many cross-border e-commerce stores registered by Chinese companies (with some sellers operating as many as hundreds of stores) had long been filing corporate income tax returns using the “zero-declaration” method, failing to accurately report their actual profits even when the stores were profitable.

Following the release of the document on July 15, 2024, the platform completed its data reporting between September and October. The big data system of the Golden Tax Phase IV initiative quickly identified discrepancies between “the platform’s reported revenue and the amounts declared by enterprises,” resulting in a large number of sellers receiving reminder text messages from the tax authorities. This rendered the gray-area practice of filing zero-revenue returns completely ineffective.

It is worth noting that the scope of Document No. 15 covers domestic e-commerce platforms such as Taobao, JD.com, and Douyin, as well as cross-border e-commerce platforms such as Amazon and eBay. Among these, stores on overseas platforms registered by Chinese companies (the third category of e-commerce scenarios) are the primary focus of this regulatory initiative, while stores registered by overseas companies are not currently required to submit information and will not be directly affected in the short term.

● Document No. 17: Standardizing the Regulation of Freight Forwarders and Providing Endorsement for Sellers’ Export Processes

While Document No. 15 enabled tax authorities to access sellers“ ”revenue-side“ data, Document No. 17 helps sellers improve their ”cost-side“ compliance documentation by regulating the freight forwarding industry. The cross-border e-commerce industry has long been plagued by the widespread practice of ”invoice-only exports,” in which sellers export goods via freight forwarders using the “double clearance” method, but the company owning the online store lacks corresponding logistics records for the goods, resulting in a mismatch between revenue and costs.

The core requirement of Document No. 17 is that when freight forwarding companies report their revenue, they must distinguish between their own service revenue and the cargo revenue of the shippers, and accurately report the shippers’ actual information. While this regulation may appear to increase compliance costs for freight forwarders, it actually provides crucial support for cross-border e-commerce sellers—by relying on the accurate information reported by freight forwarders, sellers can prove ownership of exported goods, legally record the cost of goods in their store’s corporate accounts, and establish a basis for subsequent tax filings.

Following the introduction of the policy, the focus of penalties for “export invoicing fraud” shifted to freight forwarders, forcing the industry to adopt standardized practices. For sellers, this means they will no longer need to resort to gray-area methods to prove that goods have been exported; instead, they can complete cost accounting based on compliant freight forwarding records. This is another positive aspect of Document No. 17 beyond its regulatory impact.

02 Current Key Financial and Tax Challenges in Cross-Border E-Commerce

1. Discrepancies Between Income and Tax Returns Highlight the Risk of Tax Audits

Since the implementation of Document No. 15, the biggest challenge has been the conflict between “revenue transparency” and “non-compliant reporting.” Sellers who previously filed zero or underreported returns now face a situation where the tax authorities have access to their platform revenue data; if they cannot provide a reasonable explanation for the discrepancy, they may face risks such as fines and back taxes. Even more concerning is that some sellers operate hundreds of stores, each with high turnover but without any compliance framework in place. If audited, the amount of back taxes owed could deal a fatal blow to their businesses.

2. Lack of evidence regarding export links makes cost accounting difficult

For a long time, “invoice-based exports” have prevented sellers from providing compliant documentation for the export of goods. Even though Document No. 17 standardized freight forwarder declarations, some sellers still face the problem of freight forwarders being unable to provide valid logistics records. This makes it difficult to prove the correspondence between exported goods and store revenue, thereby preventing them from legally accounting for costs and leading to the awkward situation of “having revenue but no costs” during tax filing.

3. Loopholes in the traditional compliance framework lead to non-compliant profit repatriation

The traditional compliance structure commonly used in the cross-border e-commerce industry typically involves ODI (Overseas Direct Investment) filing, whereby a Chinese company invests in a Hong Kong company, which then controls the overseas online stores. However, most sellers have only established the basic framework of this structure while overlooking critical details: they have failed to consolidate all export operations from their online stores under an import-export company for compliant customs declaration, or have failed to repatriate the Hong Kong company’s profits to mainland China as required. Instead, they have concealed these profits in overseas companies, which essentially constitutes tax evasion and has become a key focus of current tax audits.

4. Challenges in Export Tax Rebate and Tax Exemption Procedures

Export tax rebates are a critical component of cross-border e-commerce compliance, but practical implementation is fraught with challenges: On the one hand, the multi-store model complicates the rebate process, making it difficult for small-scale sellers to complete; on the other hand, some sellers source goods from 1688 or small suppliers and are unable to obtain compliant invoices, thereby failing to meet the eligibility requirements for tax rebates. Furthermore, the review period for first-time export tax rebate applications can take as long as 1–2 years, deterring sellers who urgently need to achieve compliance. While the 1039 market procurement trade method is suitable for small, family-run businesses, it is not appropriate for sellers operating multiple stores on a large scale, as doing so would expose them to higher risks.

5. Risks Associated with VAT Status Determination

For sellers, VAT status determination is currently one of the most critical risk factors. If a company is classified as a general taxpayer, it must pay VAT at a rate of 13%, which could be a “devastating blow” to cross-border e-commerce businesses operating on slim profit margins. The industry’s top concern right now is whether revenue from multiple stores will be aggregated or accounted for separately. This determination will directly impact a company’s tax costs and its ability to survive.

03 Guidance on Tax and Financial Compliance: Short-Term Emergency Measures and Long-Term Planning

● Short-term measures: Filing amended returns and claiming export tax exemptions to mitigate immediate risks

In light of the current audit pressure, the key to short-term compliance is “proactively filing amended returns + opting for tax-exempt exports.” Most sellers can no longer sustain their previous practice of filing zero returns; they should proactively communicate with the tax authorities, truthfully file supplementary returns for their store’s revenue, and pay taxes in accordance with regulations. It is important to note that the key focus at this stage is “paying taxes in good faith,” not evading tax obligations; providing a reasonable explanation for discrepancies in past filings is crucial.

Given that export tax rebates are unlikely to be implemented in the short term, tax-exempt exports are a more viable option. Tax-exempt exports do not require complex tax rebate procedures; companies need only apply for the relevant qualifications to legally mitigate VAT risks. At the same time, by utilizing freight forwarding records standardized under Document No. 17, companies can complete cost accounting and ensure that “revenue and costs” are properly matched. Furthermore, if a company is unable to handle compliant exports on its own, it can engage a comprehensive foreign trade service provider to act as an agent for export tax rebate services. Although this will incur additional costs and require foreign exchange to be repatriated to the service provider first, it can provide a short-term solution to compliance challenges.

● Mid-Term Plan: Establish a compliance framework and standardize profit repatriation

The key to mid-term compliance lies in establishing a comprehensive financial and tax structure and strictly enforcing profit repatriation procedures. The “ODI filing + Hong Kong company + import-export company” structure commonly adopted by listed cross-border e-commerce companies remains a useful model, but it is essential to avoid the operational loopholes that have arisen in the past:

▪ First, you must complete ODI registration to legalize your overseas investment.

▪ Second, establish an import-export company to centralize the export operations of all stores and complete the export of goods through compliant customs clearance (with the option of a tax refund or tax-exempt status).

▪ Finally, once a Hong Kong company generates profits, it must repatriate those profits to mainland China in accordance with regulations. If it is truly necessary to retain the profits overseas, the company must provide the tax authorities with a reasonable justification to avoid a tax audit triggered by the concealment of profits.

It is worth emphasizing that the core of building this structure is “compliance down to the details.” Simply replicating the framework without standardizing customs declarations or ensuring profit repatriation essentially constitutes tax evasion. Sellers must follow the comprehensive operational procedures of publicly traded companies to ensure that every step complies with the requirements of the State Taxation Administration.

● Long-term goal: Improve the end-to-end evidence chain to align with policy guidelines

In the long run, the key to tax and financial compliance in cross-border e-commerce lies in establishing a closed-loop chain of evidence covering the entire process—from procurement to export, sales, and payment collection. From obtaining invoices during the procurement stage, to customs declaration records and freight forwarding documents during the export stage, to platform data and payment records during the sales stage, every link in the chain must be consistent and traceable to ensure alignment with the tax authorities“ compliance standards.

When selecting a customs declaration method, sellers should make a reasonable decision based on their own scale and business model: 0110 (General Trade), 9610 (Cross-border E-commerce B2C), and 9810 (Cross-border E-commerce B2B) are the most commonly used compliant methods; 1039 (Market Procurement Trade) is only suitable for sellers engaged in small-scale, sporadic purchases; operators with large-scale, multi-store operations should use this method with caution; 9710 (Cross-Border E-Commerce B2B Direct Export) is suitable for pure B2B business models.

In addition, sellers need to shift their business mindset and incorporate financial and tax costs into their product pricing systems. Sellers who began factoring taxes and fees into their costs three years ago and selected compliant, profitable products are actually better positioned to navigate the current environment of strict regulation—and this is precisely where the long-term value of compliant business operations lies.

04 Key Reminders and Compliance Principles

1. Adhere to policy guidelines and reject underhanded tactics

At this stage, the only reliable source of information for sellers is the official announcement from the State Taxation Administration. Do not be misled by false promises of “100% tax avoidance” or “handling the tax authorities.” The regulatory logic behind the Golden Tax Phase IV initiative is “data transparency.” Any attempt to evade taxes through underhanded means will face greater risks—ranging from tax back payments and fines to criminal liability—making it a case where the costs far outweigh the benefits.

2. Categorize risk stages and respond with targeted measures

Compliance rectification should be divided into three phases: For past violations, companies must proactively communicate with the tax authorities, provide reasonable explanations, and pay any back taxes; for current operations, they must immediately cease non-compliant practices such as filing zero tax returns and adopt either the export tax exemption or compliant tax refund model; and for future operations, they must establish a compliance framework in advance, strengthen the chain of evidence, and ensure that profits are repatriated legally.

3. Pay close attention to VAT registration and plan ahead

VAT status determination is currently a key focus in the industry, and the method used to account for revenue across multiple stores—whether through consolidated or separate accounting—will directly impact a company’s tax burden. Sellers should closely monitor subsequent guidance from the State Taxation Administration, review their store operation models in advance, and, if necessary, adjust their business structure to avoid falling into operational difficulties after being classified as general taxpayers.

4. Compliance is a long-term trend; the sooner you plan for it, the sooner you’ll reap the benefits.

Tax and financial compliance in cross-border e-commerce is not a short-term measure, but rather an essential requirement for the industry’s sustainable development. From the U.S. tariff disputes to the tightening of domestic tax and financial regulations, the industry is moving away from “unregulated growth” and entering a phase of standardized development. Sellers should abandon any hope of getting away with non-compliance and view compliance as a core competitive advantage, achieving long-term profitability through lawful business operations.

05 Conclusion

The issuance of Document No. 15 and Document No. 17 marks the shift in cross-border e-commerce tax compliance from “optional” to “mandatory.” Big data oversight under the Golden Tax Phase IV initiative has made revenue transparent, while standardized freight forwarding practices have ensured the traceability of the export supply chain—leaving no room for traditional gray-market operations. For sellers, the most pressing task at present is to address compliance issues head-on by proactively filing back taxes and completing export documentation. In the short term, they should mitigate risks by taking advantage of export tax exemptions; in the medium term, they should establish a compliance framework; and in the long term, they should build a comprehensive evidence chain covering the entire supply chain.

Tax and financial compliance is not a heavy burden, but rather the cornerstone of a company’s healthy development. Sellers who plan ahead and operate in compliance will stand out amid industry consolidation. In the future, only by aligning with policy directions and adhering to compliance standards will companies be able to move more steadily and go further in the cross-border e-commerce arena.

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