In 2026, the State Taxation Administration issued Announcements No. 15 and No. 17, setting forth new requirements for the financial and tax management of cross-border e-commerce.

Announcement No. 15 stipulates that online platforms must report sellers’ identity information and revenue data to the tax authorities. This requirement applies to both domestic platforms (such as Taobao, JD.com, Pinduoduo, and Douyin) and international platforms (such as Amazon, eBay, AliExpress, and Temu), provided that these platforms provide services within China.

Announcement No. 17 requires export agencies to disclose information about the actual parties commissioning the exports. These two provisions form a complete data chain, enabling tax authorities to cross-verify the authenticity of the data reported by enterprises.

01 Compliance Risks Faced by Companies

Non-compliance with financial and tax regulations can lead to the following risks:

▪ Tax penalties: You will be required to pay back taxes, late payment penalties, and substantial fines.

▪ Criminal Liability: In serious cases, criminal liability may apply.

▪ Damage to corporate reputation: Impact on consumer and partner trust

▪ Financing Challenges: Difficulty in securing investment or going public

Frequently asked questions include:

▪ Concealing income by receiving payments through personal accounts

▪ Inaccurate cost accounting

▪ Disorganized invoice management

02 Four Compliance Models and Operational Approaches

The following four models are applicable to most cross-border businesses. Companies can choose the model that best suits their specific invoice circumstances, or combine multiple models as needed.

1. Export Tax Rebate Model (Special VAT Invoices)

2. Tax-Exempt Export Model (Standard Invoice / No Invoice in Comprehensive Pilot Zones)

3. 1039 Market Procurement Model (Individual Business Owners Without Invoices)

4. Hong Kong Company Procurement + Service Provider Model (Compliant Without Invoices)

● Export Tax Rebate Model (Special VAT Invoices)

Applicable Scenarios: Enterprises eligible to obtain special VAT invoices, such as manufacturing companies and legitimate foreign trade companies, whose business primarily involves general trade or compliant cross-border B2B e-commerce.

How to Use:

▪ When making a purchase, require the supplier to issue a special VAT invoice that matches the goods declared for customs clearance (with identical names and quantities)

▪ Declare using codes 0110 (general trade), 9710 (B2B direct exports), and 9810 (exports via overseas warehouses)

▪ Collect customs declarations, foreign exchange receipts, and special VAT invoices, and file a return under the “Exemption, Offset, and Refund” (for manufacturing enterprises) or “Exemption and Refund” (for foreign trade enterprises) schemes.

Advantage:

▪ Profits can be boosted through tax rebates (e.g., an 8-point invoicing cost corresponds to a 13-point tax rebate, resulting in a net profit of 5 points)

Note: Invoice compliance requirements are extremely strict.

● Tax-Exempt Export Model (Standard Invoice / No Invoice in Comprehensive Pilot Zones)

Application:

▪ Suppliers can only provide standard invoices

▪ Companies registered in cross-border e-commerce pilot zones to engage in 9610 (retail exports) and 9810 (exports via overseas warehouses) (difficult to establish a presence in Shenzhen)

How to Use:

▪ Standard Invoice Scenario: Based on the filing of a standard invoice, VAT is exempted at the export stage (input tax cannot be offset).

▪ 9610 / 9710 / 9810 / 0110 / 1210 (bonded e-commerce) are all acceptable

Features:

▪ Logistics costs are higher than those for general trade, squeezing profit margins

● 1039 Market Procurement Model

Applicable scenarios: Small shipments, mixed cargo, and goods without invoices. In pilot cities, customs clearance is processed through individual business operators, with the value of each shipment not exceeding $150,000.

How to Use:

▪ Register as a sole proprietor in a pilot area and complete market procurement filing

▪ Use Form 1039 for customs declaration; purchases without invoices are exempt from tax

▪ Corporate income tax is assessed on a fixed-rate basis

Features:

▪ No invoices are required for tax-free status, and the overall tax burden is low (taxes on 1 million in exports amount to approximately 5,000–15,000 yuan)

▪ It is extremely difficult to set up operations in Shenzhen due to geographical and cargo value restrictions.

▪ Must operate on-site in the pilot locations

● Hong Kong Company Procurement + Service Provider Model (Compliant Without Invoices)

Applicable Scenarios: Medium- to large-sized enterprises (with annual export revenue of 20 million or more) that make purchases without invoices and need to mitigate domestic tax pressures while ensuring the compliant repatriation of foreign exchange.

How to Use:

▪ A Hong Kong company purchases directly from a supplier in mainland China that does not issue invoices and pays for the goods

▪ Hong Kong companies may apply for an “offshore exemption” (if suppliers or customers are not Hong Kong entities and business activities do not take place in Hong Kong, they may be exempt from the 16.51% TP3T profits tax)

▪ Establish a service company in mainland China to provide cross-border services—such as supply chain management and technical support—to Hong Kong companies, and legally repatriate foreign exchange to mainland China based on the “Tax Exemption Filing for Cross-Border Taxable Transactions.”

Features:

▪ Dual tax optimization (tax-exempt status in Hong Kong + tax-exempt status for domestic services), compliant repatriation of funds

▪ A dual-entity structure linking Hong Kong and the mainland must be established

▪ For Hong Kong offshore exemptions, complete business documentation (contracts, shipping documents) must be retained, and service pricing must be reasonable.

03 Step-by-Step Instructions

1. Map out the business model

First, you need to clarify the company’s business model and select the appropriate compliance path based on the input invoices:

▪ Eligible for special invoices: Calculate the cost including the invoice surcharge and select the export tax refund model

▪ If you can only obtain a standard invoice or no invoice: Select the export duty-free option or the Form 1039/Hong Kong company model

2. Establish a Compliance Framework

A well-designed structure can make transaction flows clearer, facilitating the export of goods and the collection of payments. Care must be taken to avoid issues related to affiliations between the parent company and the Hong Kong company, as well as between the retail company and the Hong Kong company.

3. Practical Implementation of Compliance

This includes preparing import and export qualifications, selecting customs clearance methods, filing for export tax refunds (or exemptions), receiving foreign exchange, accounting, and filing tax returns.

Key Points:

▪ Export Tax Rebate: You must prepare all necessary documents, such as customs declaration forms, delivery orders, and shipping documents.

▪ Foreign Exchange Receipts: Ensure that the foreign exchange receipt route matches the goods export route

▪ Accounting Treatment: Accurately record sales revenue, as well as logistics costs for the first and last legs of the shipment

04 Cross-Regulatory Profit: A One-Stop Compliance Solution

Amid the global wave of cross-border e-commerce, compliance is the cornerstone of steady growth. With years of deep expertise in the field of cross-border compliance, KuaiGuiYing leverages its extensive industry experience and professional team to provide sellers with customized, end-to-end, one-stop compliance solutions:

▪ Global VAT Compliance: We provide efficient, end-to-end services—from tax ID registration and filing to management and deregistration; we promptly handle tax correspondence, assist with EORI applications and inquiries, and accurately manage tax risks.

▪ European EPR/Product Compliance: We specialize in handling European EPR registration and reporting, and provide authorized representative services in Europe, the UK, and the U.S.; we assist with EU energy efficiency labeling and climate-friendly certification, helping sellers easily adapt to European market regulations.

▪ Overseas Business and Tax Compliance: We offer full-cycle services covering overseas company registration, investment filing, annual audits, and more; we also provide professional support for offshore account applications, as well as changes to company equity and directors.

▪ Global Intellectual Property Compliance: We provide global trademark, patent, and copyright registration services, as well as trademark reexamination services, to comprehensively protect your brand assets and give you peace of mind as you expand into international markets.

Previous Recommendations

▪ New E-commerce Tax Regulations Take Effect in 2026: China’s Cross-Border Sellers Shift from a “Cash Flow-Oriented” to an “Order-Oriented” Approach”

▪ Implementation of Documents No. 15 and No. 17: Financial and Tax Compliance for Cross-Border E-Commerce Shifts from “Optional” to “Mandatory”

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

END

Follow the “Qicaiying Cross-Border Compliance Consulting” video channel to see more great content

The articles on this official account are provided for cross-border compliance reference only; please consult a professional advisor for specific tax treatment.

Scan the QR code to add us on WeChat (WeChat ID:jxhcyb) or call our customer service hotline18148556832, Get a free copy of the “Self-Checklist for Four Cross-Border E-Commerce Compliance Models” and a one-on-one compliance assessment plan.