surname CongJuly 1It has been exactly17 days. Over the past 14 days, numerous cross-border e-commerce sellers in Shenzhen and Guangzhou have received tax risk warning letters—the system automatically compares platform transaction records with reported income, and if the discrepancy exceeds 10%, an alert is immediately triggered.

This article analyzes five key indicators of the new regulations’ implementation to help you assess whether your books can withstand an audit under the Golden Tax Phase IV initiative.

💡 If you’ve also received a tax risk alert, or if you’re unsure whether your tax return data will hold up under scrutiny, add Qicaiying’s customer service WeChat account: qcygscszk, or call 18676749275 to get a free financial and tax compliance assessment.

I. Taxation Based on Audited Accounts—No Exceptions

Starting in July 2026, all cross-border e-commerce entitiesUniform Implementation of Tax Calculation Based on Audited AccountsThe

The old approach of ”fixed-rate taxation and paying taxes based on a set rate” has been completely phased out.

To put it simply: your procurement costs, logistics expenses, advertising expenditures, and warehouse rent—every single one must be supported by a valid invoice for bookkeeping purposes.Expenses without supporting documentation cannot be deducted from costs.The

If costs cannot be offset, profits are adjusted upward. When profits are adjusted upward, more income tax must be paid.

This isn't a discussion about ”whether or not to comply.” Rather, it's about:The cost of noncompliance can now be quantified.That's it.

II. Platform Data Integration and Automatic Comparison of the Four Flows

The biggest change in the new regulations isn't the tax rate; it'sData IntegrationThe

Phase IV of the Golden Tax System has already been integrated with 28 government and financial systems. Data from five departments—taxation, customs, banking, foreign exchange, and market regulation—is now automatically cross-checked within a single system.

How exactly do you compare them?

The system automatically pulls up these four data points and compares them.The difference exceeds 10%; the alert is triggered.The

It’s not a manual spot check. The system automatically scans, captures, and pushes the data.

In the past, you might have said, ”The tax authorities can’t access that much data.” Now, the platforms are proactively submitting the data.

📌 Is there a discrepancy between your total platform order value and your reported income? Not sure if the discrepancy exceeds 10%? Add Qicaiying on WeChat (qcygscszk) to get a one-on-one data comparison analysis.

III. The "split-subject" approach no longer works.

Many sellers follow this approach: they set up one company per platform, keeping each company’s revenue under 5 million to qualify for the preferential treatment granted to small-scale taxpayers.

Since the new regulations took effect, this line of reasoning has been debunked.

Tax authorities are now usingIP address, warehouse address, financial transaction history, actual controllerConduct cross-checks across four dimensions. Multiple entities under the same owner, sales revenueAggregatedThe

If total revenue exceeds 5 million for 12 consecutive months, the business is automatically reclassified as a general taxpayer that month. There is no transition period and no grace period.

What’s more severe is that—if it is determined that the entity was intentionally split up to evade taxes, the penalties will be applied retroactively.3 yearsOrders, by13%The full amount of VAT will be collected retroactively. This isn’t like in the past, when ”paying a little extra tax was enough”; it’sThe full amount of 13%The

IV. Some people are already footing the bill

Just 14 days after the new regulations took effect, sellers in Shenzhen have already been specifically targeted.

A typical example: A seller in Shenzhen operates on three platforms—Amazon, Temu, and Shopee—but has registered only one small-scale company. The total transaction volume across these platforms exceeds18 million, with reported income of less than2 millionThe

With the "Golden Tax Phase IV" system, we pulled up the order details from the three platforms and laid them out on the table alongside the customs declaration records and the bank’s payment transaction history—the discrepancy was clear down to two decimal places.

Results:The total amount of back taxes, late payment penalties, and fines exceeds one millionThe

It's not about whether it will be exposed. It'sWhen will it be revealed?The

V. Four Things to Do Now

First, data comparison.Export the order reports from all platforms for the past 1–2 years, compile them with your tax returns, and calculate the difference. If it exceeds 10%, file an amended return proactively.

Second, issuing replacement invoices.Purchasing, logistics, warehousing, advertising—make sure all invoices are in order. We can no longer rely on ”recording transactions without invoices” to cover the 2026 books.

Third, corrective actions by the responsible entities.Take stock of all the companies and stores under your name. If there are multiple entities used to split operations, immediately consolidate them or restructure your operations. It’s not a question of ”whether to make changes,” but rather ”whether to make changes now or wait until you’re audited.”

Fourth, customs declaration regulations.All shipments from overseas warehouses must be classified under HS code 9810. Stop trying to get away with using 0110. The route involving export invoices and “double clearance with tax included” can trigger a tax audit at any time.

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Qicaiying Group | Cross-Border E-Commerce Financial and Tax Compliance Service Provider

Specializing in end-to-end financial and tax compliance for cross-border e-commerce companies: compliance reviews of input VAT invoices, reconciliation of export revenue with cash flow, compliance assessments of related-party transactions in multi-entity structures, and historical tax risk assessments and remediation plans.

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Founded in 2015 and headquartered in Shenzhen, Qicaiying Group is a leading provider of corporate services and tax compliance solutions in China.

The Group is deeply committed to providing services across the entire corporate lifecycle. Its core business areas include: business registration, bookkeeping services, tax compliance, overseas company registration (Hong Kong, the U.S., Singapore, Mexico, etc.), cross-border structuring, outbound direct investment (ODI) filing, overseas tax planning, bank account opening assistance, and identity planning.

Over the past decade, Qicaiying has served more than 10,000 corporate clients and has accumulated solid practical experience in key areas such as corporate structuring in Hong Kong and overseas, cross-border tax and financial compliance, and corporate accounting management. The Group boasts a team of seasoned financial and tax advisors who closely monitor changes in domestic and international tax systems and regulatory trends, providing clients with one-stop solutions ranging from structural planning to implementation.