Traditional Trade vs. Cross-Border E-Commerce:

▪ Transaction Parties: Traditionally dominated by B2B; in cross-border e-commerce, B2C and C2C are predominant

▪ Order Volume: Traditional business involves a small number of large orders, while cross-border e-commerce involves a large number of small orders

▪ End Customers: Traditional business customers, individual consumers in cross-border e-commerce

▪ Payment Methods: Traditional bank transfers, collection via cross-border e-commerce platforms, and third-party payment services

▪ Invoice Management: Traditional systems are comprehensive, but cross-border e-commerce businesses have difficulty obtaining them

Key Tax Risks:

▪ Non-compliance with export tax rebate regulations: failure to file claims in a timely manner or filing inaccurate claims

▪ Unresolved overseas tax issues: Lack of tax compliance in the destination country or region

▪ Non-compliant capital repatriation: Cross-border capital flows lack supporting documentation

▪ Personal income tax issues: Employees working abroad, commissions earned by social media influencers, etc.

▪ Transfer pricing risk: Unreasonable pricing of transactions between related parties

01 Key Points for Export Tax Rebate Compliance

Basic Requirements for Export Tax Rebates (According to Current Regulations):

▪ Eligibility: The enterprise must have export rights and be a general VAT taxpayer.

▪ Scope of Goods: Goods subject to value-added tax and consumption tax

▪ Requirements for Departure: The goods have been cleared through customs for departure (export)

▪ Foreign exchange receipt requirements: Foreign exchange has been received or is deemed to have been received

▪ Complete documentation: Obtain legally valid purchase and export documents

For businesses in the Guangzhou area, the practical urgency of this issue is particularly acute.

Analysis of Cross-Border E-Commerce Export Models:

▪ 9610 (Direct Mail): B2C direct mail, individual package clearance → Tax refund eligibility is complex and requires review

▪ 9710 (B2B): Cross-border e-commerce B2B direct exports → Eligible for tax refunds

▪ 9810 (Overseas Warehouse): Bulk exports to overseas warehouses → Eligible for tax refunds

▪ 0110 (General Trade): Traditional B2B exports → Mature market; eligible for tax rebates

● Tax Treatment Under the 9610 Model

Key Issue: When exporting individual packages, it is difficult to obtain a customs declaration form for each item. This must be handled through the “list-based release and consolidated declaration” process; after filing a consolidated declaration, a formal customs declaration form is obtained, and a tax refund is then applied for.

Practical points:

▪ Select a compliant 9610 customs broker

▪ Ensure that the order, payment slip, and shipping slip match“

▪ Submit reports in a timely manner to obtain an official customs declaration form

▪ Keep all export documents on file for future reference

● Tax Treatment Under the 9810 Model

Advantages: Bulk exports allow you to obtain official customs declarations; the tax refund rate is typically higher than that of direct mail; once funds are recovered, you can apply for a tax refund in compliance with regulations.

Practical points:

▪ Plan your overseas warehouse network in advance

▪ Handle export accounting and tax filings properly

▪ Pay attention to tax handling after sales from overseas warehouses

▪ Conduct regular inventory counts at overseas warehouses

02 Overseas Tax Compliance

Tax Requirements for Key Target Markets

U.S. Market:

▪ Sales Tax: “Economic ties” exist across states”

▪ Income Tax: Has a physical presence in the United States

▪ Customs Duties: Imported goods are subject to

Economic Nexus Criteria: Sales exceeding $100,000, or more than 200 transactions.

EU Market:

▪ VAT (Value-Added Tax): Holding inventory or making sales within the EU

▪ Customs Duty: Imported goods are subject to customs duties

▪ Income Tax (Corporate Tax): Has a permanent establishment in the EU

OSS/IOSS Filing: Simplify VAT compliance across multiple EU countries with a one-stop filing service.

Southeast Asian Market:

▪ Vietnam: You must register for an E-Tax account

▪ Indonesia: An NPWP tax ID number is required

▪ Malaysia: SSM registration and e-invoicing required

▪ Singapore: A GIRO account is required for filing

Overseas Tax Compliance Strategies

Strategy 1: Advance Planning

▪ Before entering a new market, familiarize yourself with local tax requirements

▪ Choose the appropriate entry model (direct sales vs. platform vs. third-party)

▪ Assess the impact of tax costs on the business model

Strategy 2: Local Compliance

▪ Establish the necessary legal entities in the target market (if required)

▪ Complete tax registration and filing in a timely manner

▪ Hire a local professional tax advisor

Strategy 3: Cost Optimization

▪ Make effective use of tax treaty benefits

▪ Optimize transfer pricing strategies

▪ Take full advantage of R&D and innovation tax incentives in various countries

03 Compliance with Cross-Border Capital Repatriation Regulations

Compliance Path:

▪ Official bank channels: Suitable for large-scale repatriation of funds; complete business documentation must be provided

▪ Third-party payment: For e-commerce platform payments, select a compliant payment provider

▪ Supply Chain Finance: Trade financing, which requires a genuine trade background

Compliance Documentation Requirements (to be prepared when funds are repatriated):

▪ Export Declaration Form: Proof that the goods have legally left the country

▪ Proof of foreign exchange receipt: Bank statement issued by the bank

▪ Sales Contract/Order: Proof of the authenticity of the transaction

▪ Logistics Documents: International Logistics Tracking

▪ Platform Transaction History: Screenshots from the e-commerce platform’s backend

04 Frequently Asked Questions

Q: Can I apply for an export tax refund under the 9610 direct mail model for cross-border e-commerce?

A: Yes, but the process is more complex than general trade. The 9610 model requires the “list-based release and consolidated declaration” method: ① Work with a customs broker qualified for 9610; ② Ensure that the order, payment, and shipping documents match (the “three-document match”); ③ File a consolidated monthly declaration to obtain the official customs declaration form; ④ Apply for an export tax refund using the customs declaration form. The key is to select a compliant service provider and retain complete business documentation.

Q: What taxes must cross-border e-commerce businesses pay overseas?

A: It depends on the target market. The main tax types include: ① United States—sales tax (rates vary by state), customs duties, and income tax (if there is a physical presence); ② European Union—VAT (value-added tax), customs duties, and corporate income tax (if there is a permanent establishment); ③ Southeast Asia—Regulations vary significantly by country, but corporate income tax and VAT are generally in place. It is recommended to consult local tax professionals before entering each new market.

Q: How can funds in the platform’s third-party payment account be repatriated in compliance with regulations?

Answer: Compliance Procedures: ① Exchange foreign currency through a third-party payment institution licensed for cross-border payments (e.g., LianLian, PingPong, etc.); ② Provide complete sales records, order details, and platform transaction records as proof of the authenticity of the business; ③ Ensure that each foreign exchange transaction is accompanied by a corresponding export customs declaration or compliant supporting documentation; ④ Retain complete records of fund flows for future reference. Never repatriate funds through underground money exchanges or individual currency exchange channels.

Q: What is the tax risk that cross-border e-commerce companies are most likely to overlook?

Answer: The three most common blind spots: ① Failure to withhold and remit individual income tax on commissions paid to overseas influencers/KOLs—this is receiving increasing attention during domestic tax audits; ② Tax treatment of inventory in overseas warehouses—under the 9810 model, tax compliance in the destination country following the sale of goods from overseas warehouses is often overlooked; ③ Transfer pricing issues—if pricing between domestic companies and their overseas affiliates is unreasonable, there is a risk of double taxation.

05 Individual Income Tax Compliance

Common Risk Areas:

▪ Influencer Commissions: Failure to withhold individual income tax when paying commissions to overseas influencers

▪ Employees Working Abroad: Tax Treatment of Compensation for Chinese Employees Working Abroad

▪ Overseas Income: Failure to report overseas income

Compliance Recommendations:

▪ Establish a comprehensive commission payment process

▪ Require overseas payees to provide proof of tax identification

▪ Withhold and remit individual income tax in accordance with regulations

▪ Keep all payment receipts

▪ Focus on Tax Issues Related to Cross-Border Employee Assignments

▪ Understand the tax residency determination rules of various countries

▪ Reasonably schedule the duration of the assignment and the compensation structure

▪ Coordinate dual reporting

06 Cunqin Law & Tax’s Cross-Border E-Commerce Services

As a professional organization with extensive experience in the cross-border e-commerce sector, we offer the following services:

▪ Optimization of Export Tax Rebates: Design of tax rebate schemes, optimization of tax rebate processes

▪ Overseas Compliance Consulting: Tax Registration and Filing in Various Target Markets

▪ Fund Repatriation Plan: Design of compliant repatriation channels; guidance on documentation

▪ Annual Tax Advisory Services: Day-to-day tax consulting, risk alerts

Service Advantages:

▪ 18 years of practical experience: Familiar with various trade models and tax treatment

▪ Cross-border specialist team: Tax experts covering major target markets

▪ One-stop service: Comprehensive coverage from architectural design to implementation

concluding remarks

Tax compliance in cross-border e-commerce is not a burden, but rather the cornerstone of a company’s sustainable development. Compliance is the best risk management strategy and also the most cost-effective approach.

Recommendations for cross-border e-commerce companies:

▪ Establish a systematic tax compliance framework

▪ Conduct regular tax health checks

▪ Choose a professional agency to provide support

Previous Recommendations

▪ Analysis of Announcements No. 15 and No. 17 of 2026: Four Compliance Models for Cross-Border E-Commerce and Their Practical Implementation

▪ New E-commerce Tax Regulations Take Effect in 2026: A Shift from a “Revenue-Based” to an “Order-Based” Approach”

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

END

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