A lot of people in the cross-border e-commerce business have been asking me the same question lately: “Isn’t the 9810 customs supervision model supposed to be a godsend for expanding overseas? So why, when I actually tried it, did my accountant pull their hair out, and instead of getting a tax refund, I ended up with a whole bunch of headaches?”

Today, let’s close the door and speak frankly. I’m not here to read you the policy—you can easily find the policy provisions online. Today, as a consultant who has seen too many companies fall into pitfalls on the front lines, I’m here to help you figure out why, even though the government has provided a compliant export channel, you just can’t seem to make it work.

If you're planning to use the 9810 right now, or if you're already stuck in the middle of the process, this article is worth reading twice.

Pitfall #1: What You Think Is “Refund the Excess, Pay the Shortfall” Is Actually “Settling Accounts After the Fact”

This is the part that confuses almost all new business owners. When stocking up at a 9810 overseas warehouse, how should you fill in the price on the customs declaration form if the goods have been shipped but not yet sold?

Many business owners slap their thighs and say, “Well, let’s just come up with an estimate then!”

All right, let’s use this “estimate” to run some numbers:
Suppose your customs declaration shows estimated sales of 1 million for a shipment. To manage your cash flow, you apply for an export tax refund based on that 1 million. However, the reality overseas is that after the platform deducts its commission and advertising fees—and applies some discounts—you actually only receive 700,000 in your account.

This is where many business owners fall into a common misconception. They assume that the tax authorities will simply pick a random figure between 1 million and 700,000 to determine their tax liability, but this is a huge mistake.

The truth is harsh, and the legal rules are very clear: these are two completely separate paths:

1. When it comes to VAT, the rule is “any advance refund must be repaid.” You filed your tax return reporting 1 million, so the tax authority initially issued you a tax refund based on 1 million. However, when it comes time for the annual tax settlement the following year, you must provide solid evidence to prove that you only sold 700,000. The tax corresponding to the 300,000 overrefunded earlier,Every penny must be repaid in full. Thinking of cutting corners? The Golden Tax System is way faster than your store’s backend refresh rate.
2. When it comes to corporate income tax, the only factor that matters is “actual cash receipts.” The tax authorities only recognize the 700,000 that you’ve actually received. As for the inventory still sitting in overseas warehouses and unsold, it isn’t considered your income at all, so you don’t have to pay taxes on it—you don’t need to worry about double taxation in this regard.

But then came the biggest headache of all—reconciliation.
Just think about it: a single customs declaration covers thousands of SKUs spread across hundreds of stores, and the fees and ad cost allocations vary for each order. How are you going to prove that the 300,000 difference was caused by discounts and fees?
The vast majority of small and medium-sized enterprises’ finance teams simply can’t handle this volume of data cleansing. In the end, the books don’t balance, tax refunds are processed without proper documentation, and tax risks skyrocket.

Pitfall #2: Haphazard Pooling of Store Funds—What You Think Is Just “Moving Money from One Pocket to Another” Is Actually a Minefield

This is also a critical vulnerability that is extremely easy to detect during an audit:Consolidated payment collection across multiple stores and platforms.

I’ve seen far too many sellers who operate on a bulk-listing model—they manage dozens or even hundreds of stores, so it’s impossible for them to file customs declarations for each one individually. The usual practice is this: all the funds from these stores first pour into a third-party account in Hong Kong, and then a single transfer is made from that Hong Kong account back to the export company in mainland China to be used for the 9810 declaration. To get through inspections, they hastily sign a so-called “store affiliation agreement.”

I must emphasize this point: While it’s not impossible for this sales channel to be compliant, the barriers to entry are so high that ordinary sellers on 90% simply can’t meet them!

Earlier, a colleague tried to use the model of “Saiwei”—which went public and became a huge success—to negotiate with the tax authorities, but was flatly rejected. Do you know what the tax authorities said?
“That company is a top player in the industry. Before going public, it fully paid all back taxes for previous years and has a complete chain of evidence spanning more than a decade—including inventory records, order history, and cash flow statements. They spent a fortune to negotiate a customized settlement. You’re just a small-to-medium-sized seller—do you really think you can simply copy their cash pool model based on a single, simple agreement?”

Simply using a Hong Kong account as a conduit, along with a few pages of a simple agreement, will absolutely not be accepted by tax authorities in the vast majority of jurisdictions. This is because there are no universal tax laws to fall back on; everything depends on the local tax administration’s interpretation. In the event of an audit, this vague fund consolidation practice could easily be deemed to involve underreported income—and having to pay back taxes and late payment penalties would be the least of your worries.

Pitfall #3: Is the tax refund for exports really that appealing? The workload involved could completely overwhelm the finance department.

9810 now supports “tax refund upon departure,” meaning you can receive your money as soon as your goods leave the country. The original intent behind this policy is excellent—it helps you improve your cash flow.

However, the devil is in the details. Policy mandates that the annual settlement must be completed by April 30 of the following year.

What makes this liquidation process so difficult? You have to clearly categorize the entire shipment:

• Which ones were actually sold? (Recalculate the tax refund based on the actual selling price);
• Which items are slow-moving and still gathering dust in the warehouse? (Sorry, I’ll return the advance tax refund I received earlier in full.)

This is a nightmare for sellers who stock their inventory. With tens of thousands of customs declarations and hundreds of thousands of SKUs, you have to link the sales volume, discounts, advertising costs, and even inventory count changes for every single item to their corresponding customs declarations.
This is no longer just a matter of adding a few finance staff members. Without a robust in-house or third-party ERP system to extract platform data, relying solely on manual reconciliation would make this an impossible task. The direct costs of compliance—system and labor—are enough to deter most small sellers looking to save money.

Conclusion: To successfully navigate the 9810 process, you must first settle these three accounts.

At the end of the day,The 9810 policy itself is entirely legitimate and serves as an effective channel for the government to support the formalization of cross-border e-commerce.

But the reason you’re hitting a wall isn’t because of the policy—it’s because you’ve run aground on three pitfalls in practical implementation:

1. The Black Hole of Spread Accounting(Discrepancies between customs declarations and payment receipts);
2. Fund Consolidation Black Hole(It is impossible to prove the legitimacy of funds from multiple stores);
3. The Reckoning Black Hole of Massive Data(The workload is overwhelming the accounting system).

Furthermore, since there are indeed differences in local tax enforcement regulations, if you don’t plan your chain of evidence (logistics records, cash flow, and order records) a year in advance and ensure your equity and business structures are compliant, and instead blindly push ahead with the 9810 filing, what awaits you later will most likely be more than just back taxes—it will be a tax audit warning notice.

In cross-border business, the only money that really counts these days is the money that ends up in your pocket. Don’t let the sweet taste of tax refunds turn into the biggest headache in your business.

If this article resonates with your current concerns, we recommend you bookmark it to revisit and reflect on it, or share it with friends in your network who are also involved in cross-border business. Let’s work together to protect our profits and earn money while staying compliant.