In June and July 2025, the State Taxation Administration issued two important documents in quick succession that are closely related to internet platforms and export enterprises:

▪ “Announcement of the State Taxation Administration on Matters Concerning the Submission of Tax-Related Information by Internet Platform Enterprises” (Announcement No. 15 of 2025 of the State Taxation Administration, hereinafter referred to as “Announcement No. 15”)

▪ “Announcement of the State Taxation Administration on Optimizing Matters Related to Corporate Income Tax Advance Payment Returns” (Announcement No. 17 of the State Taxation Administration, 2025; hereinafter referred to as “Announcement No. 17”)

Both announcements take effect on October 1, 2025, and will have a significant impact on the cross-border e-commerce industry. By addressing the revenue side (sales and reporting) and the cost side (tax refunds and advance payments), respectively, they form a stricter regulatory loop covering the entire cross-border e-commerce supply chain. Traditional models that rely on “export through third-party invoices” and “invoice circumvention” will face increasingly significant compliance challenges.

01 Policy Background: With Tighter Regulations, Cross-Border E-Commerce Enters an Era of “Look-Through” Compliance

In recent years, the role of cross-border e-commerce in China’s foreign trade landscape has continued to grow. According to data from the General Administration of Customs, the value of China’s cross-border e-commerce imports and exports exceeded 2.6 trillion yuan in 2024, representing a year-over-year increase of 14.8%.

Amid rapid economic growth, some enterprises have engaged in practices such as issuing fraudulent invoices, export transactions based on purchased invoices, and non-compliant capital repatriation, posing risks to tax administration and international creditworthiness. Announcements No. 15 and No. 17 represent key measures taken by regulatory authorities to implement “data-driven tax administration and transparent oversight”:

▪ Announcement No. 15: Requires internet platform companies to regularly report tax-related information—such as revenue, orders, and commissions—for businesses operating on their platforms, thereby enabling a comprehensive understanding of the scale of e-commerce businesses’ operations.

▪ Announcement No. 17: Further optimizes the corporate income tax advance payment filing system, clarifies the tax filing and tax refund requirements for enterprises engaged in agency exports, consignment exports, and the production and sale of export goods during the export process, and standardizes tax administration for the export process.

In other words, once the policy is implemented, the revenue, costs, and profits of cross-border e-commerce companies will all be subject to thorough scrutiny, marking the industry’s official entry into a new phase of “strict regulation and high transparency.”

02 Key Points of Announcement No. 15: Enhanced Reporting Obligations for Platform Operators

The core of Announcement No. 15 is that platform companies must submit business data on merchants operating on their platforms, including but not limited to:

▪ Revenue Information: Includes transaction volume, commissions, platform subsidies, advertising and promotion expenses, etc.

▪ Order Volume: Includes the number of completed orders, the number of return orders, the percentage of cross-border orders, and more.

▪ Business operator identification information: such as corporate or sole proprietor status, taxpayer identification number, etc.

This means that small and medium-sized cross-border sellers, who previously relied on platforms to “hide information,” will gradually lose their “regulatory blind spots.”

Impact Analysis:

▪ Increased pressure on small sellers: The practices of “personal payment collection” and “collection and payment on behalf of others,” which they relied on in the past, are no longer sustainable.

▪ Increased compliance costs for large sellers: They must verify the accuracy of their revenue and ensure consistency in their tax filings in advance.

▪ Greater platform responsibility: Leading e-commerce platforms (such as Alibaba International, JD Worldwide, SHEIN, etc.) must assume the role of “tax information reporter.”

Key Points of Announcement No. 03-17: More Refined Advance Payments and Tax Refunds at the Export Stage

Announcement No. 17 primarily addresses corporate income tax and tax refund issues in the export chain and clarifies the obligations of three categories of enterprises:

▪ Export agents: Must truthfully declare export agency business; issuing false invoices or filing declarations on behalf of others is prohibited.

▪ Entrusted export enterprises: Must provide a complete entrustment agreement, export contract, and proof of foreign exchange receipts and payments to ensure compliance with tax refund filing requirements.

▪ Manufacturing, sales, and export enterprises: These enterprises should file accurate declarations based on their actual production, sales, and foreign exchange receipts, thereby ensuring consistency among invoices, foreign exchange receipts, and tax refunds.

Impact Analysis:

▪ The export tax rebate cycle may be extended, so companies need to strengthen their invoice management and cash flow coordination.

▪ The "buy-and-ship" export model has been virtually eliminated; companies must now declare their exports through compliant export channels.

▪ Cross-border sellers using the “overseas warehouse + B2B2C” model should pay special attention to aligning foreign exchange receipt timelines with tax refund processing.

04 Analysis of the Four Major Compliance Models for Cross-Border E-Commerce Under the New Policies

Under the combined regulatory requirements of Announcements No. 15 and No. 17, cross-border e-commerce businesses need to reassess their business models. The following four models are currently common and relatively compliant options.

● 1. The 1039 Market Procurement Trade Model

Scope of Application: Small and medium-sized cross-border e-commerce businesses with a shipment value of ≤$150,000 per shipment.

Features:

▪ Procured from and exported via state-designated market clusters

▪ Exports are exempt from value-added tax, resulting in low demand for input invoices

▪ Settlements can be made through personal foreign exchange accounts, and foreign currency receipts from multiple parties are supported

Advantages: Simplified customs clearance procedures and flexible payment terms.

Disadvantages: Limited to specific markets; order value is modest; not suitable for large sellers.

● 2. 9610 Cross-Border E-Commerce Small Package Export Model

Scope of Application: Direct-to-consumer (D2C) cross-border e-commerce.

Policy Incentives:

▪ For shipments with a value of ≤5,000 yuan per consignment, customs clearance may be processed via “itemized release and aggregated reporting.”

▪ Enterprises in cross-border e-commerce comprehensive pilot zones are eligible for tax exemption without invoices or a fixed-rate corporate income tax assessment (taxable income rate: 4%).

Advantages: Short delivery routes, fast delivery times, low costs, and high flexibility.

Disadvantages: Suitable for small, high-frequency orders; not suitable for large-scale exports.

● 3. The 9810 Overseas Warehouse Export Model

Scope of Application: B2B2C model; suitable for medium- to large-sized sellers looking to establish overseas fulfillment centers.

Features:

▪ “Ship first, order later”—export to overseas warehouses first, then redistribute from there

▪ Improve logistics efficiency and reduce damage rates

Risks:

▪ Time lags between exports and foreign exchange receipts make the tax refund process more complicated

▪ Companies need to improve the integration of overseas warehouse data with domestic customs clearance and tax refund systems.

● 4. 0110 General Trade Model (Direct Procurement by a Hong Kong Company + Service Company)

Target Audience: Large sellers and brands expanding into international markets.

Procedure:

▪ Exports from a mainland company to a Hong Kong company (general trade customs declaration)

▪ A Hong Kong company acts as an overseas entity to handle fund receipts and disbursements and manage store operations

Advantage:

▪ Complies with traditional export tax rebate policies and has a clear structure

▪ Hong Kong companies offer advantages such as low tax rates, no foreign exchange controls, and convenient fund transfers

▪ Helps enhance a company’s internationalization and compliance

05 Compliance Recommendations for Cross-Border E-Commerce

▪ Coordinate with the finance and tax team in advance: Before the policy takes effect, review supply chain invoices, export tax rebate procedures, and foreign exchange receipt processes to avoid audits caused by data inconsistencies.

▪ Flexible export options: Small sellers can choose between the 1039 or 9610 models, while larger sellers should consider the 9810 overseas warehouse or the 0110 Hong Kong structure.

▪ Increased budget for compliance costs: Once the policy takes effect, cross-border e-commerce businesses will no longer be able to rely on “gray-area practices,” and companies will need to allocate additional funds for financial and tax compliance, as well as for their overseas corporate structures.

▪ Leverage digital tools: Use ERP and cross-border tax and finance SaaS platforms to enable end-to-end reconciliation across the entire process—from orders to payments, invoices, and tax refunds.

06 Conclusion

The issuance of Announcements No. 15 and No. 17 of 2025 marks the cross-border e-commerce industry’s official departure from its “gray-area” existence and its transition to a new phase characterized by transparency, compliance, and internationalization.

For cross-border e-commerce companies, this presents both a challenge and an opportunity. Those that can quickly adapt their business models and strengthen their financial and tax management will stand out in the next round of industry consolidation.

If you are interested in services such as designing cross-border e-commerce compliance models, registering a company in Hong Kong, or optimizing export tax rebates, please feel free to contact our team of professional consultants. We will help you achieve more efficient global operations within a compliant framework.

Previous Recommendations

▪ Tax Challenges and Compliance Guidelines for Cross-Border E-Commerce: From Export Tax Rebates to Overseas Taxation

▪ Analysis of Announcements No. 15 and No. 17 of 2025: Four Compliance Models and Implementation Procedures

▪ What Is Phase IV of the Golden Tax System? The Truth About “Data-Driven Taxation” That Cross-Border E-Commerce Sellers Must Know

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