How do you claim an export tax refund without input invoices? This is one of the most frequently asked questions in the cross-border e-commerce industry.

Many sellers take the customs declaration forms provided by their freight forwarders to the tax office to claim a tax refund, only to be turned away at the counter with a single question: ”Where’s the input tax invoice?”—leaving them completely dumbfounded on the spot. The goods were clearly purchased by them and were actually exported—so why should a single invoice block their path to a tax refund?

In today’s article, we’ll thoroughly explain whether you can get a tax refund without a ticket and offer you three practical solutions.

First, the conclusion: Without input invoices,The export tax rebate route is a dead end. However, ”being unable to claim a tax refund” does not mean ”there are no compliant solutions”—one of the three options below is sure to work for you.

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01 First, let’s face the reality: No ticket = No tax refund.

Many sellers have misconceptions about export tax rebates, believing that ”You can claim a tax refund once the goods have been exported.“No, that’s not it.”

What does an export tax rebate cover? It covers your procurement costs.VAT Already Paid. How do you prove you’ve paid? With a special VAT invoice. Without this invoice, there’s no record of your input tax in the tax system, so a tax refund is out of the question.

⚠️ Policy floor—no room for maneuver

The legal prerequisite for export tax rebates is ”obtaining a special VAT invoice for purchased goods and having it certified for tax credit.” This is a mandatory requirement stipulated in the policy—it is not something any intermediary can ”work around.” Anyone who promises ”tax rebates without an invoice” is either scamming you or using illegal methods; if anything goes wrong, you’ll be the one to bear the consequences.

So why do so many cross-border sellers get stuck because they ”don’t have invoices”? There are two reasons:

① Supply chain cannot issue an invoice:Many suppliers are small workshops or sole proprietorships that lack the qualifications to issue invoices, or that charge an additional tax surcharge if they do issue invoices; sellers choose not to request invoices in order to keep costs down.

② Questions Regarding Procurement Methods:Whether it’s purchasing from individual sellers on 1688, making cash purchases in person, or even having intermediaries make purchases on your behalf, the supply chain has broken down, and the invoices simply can’t be processed.

The result is this: the goods were shipped, the money was made, but the tax refund—which can easily amount toSeveral million to over ten million——I won't get a single penny backThe

Let’s be blunt: no ticket means no tax refund—it’s a deadlock that no one can break. Instead of wasting time looking for shortcuts, keep reading to find out which compliant options are available.

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02 Just how big is the gap between having a ticket and not having one?

Don't just assume that ”if you can't get a refund, you can't get a refund.” We'll use100 million in salesDo the math, and you'll see just how much this ticket is worth:

For 100 million in sales, the difference between having invoices and not having them amounts to 10 million in tax refunds plus 2.5 million in total tax liability, for a combined total of 12.5 million.That's no small amount—many sellers don't even make that much in net profit in a whole year.

So our advice is always:If you can issue an invoice, be sure to do so.. Issuing an invoice under the 0110 tax refund code is the option that maximizes benefits and ensures full compliance.

When it comes down to it, saving a little on taxes means losing ten or even a hundred times that amount in tax refunds. No matter how you look at it, it’s not worth it.

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03 What to Do If You Don't Have a Ticket? Three Options

If you really don’t have an invoice right now, or if your supply chain can’t issue one in the short term, don’t panic. While a tax refund isn’t an option, there are still three compliant alternatives, listed in order of recommended priority:

① Purchase a ticket via route 0110 for a tax refund (Saiwei 2.0 architecture)

Intended Audience:Supply chain can issue invoices (or is willing to cooperate with invoicing), annual sales20 million or more, Sellers who want to claim the full tax refund

How to do it:Establish the Savi 2.0 four-entity framework: the domestic supply chain company handles procurement and invoice acquisition; the domestic export company handles customs clearance for export (Form 0110); the overseas company receives foreign exchange; and the service company repatriates profits. Goods are legally cleared through customs by the export company, invoices are obtained in compliance with regulations by the supply chain company, and tax refunds are processed smoothly.

Key Points:The key to this approach is ”making up for the tax credit.” If your supplier can issue a special VAT invoice, even if it means paying a little extra in tax, it’s still better than losing out entirely.10 million tax refundIt's much more cost-effective. Among the clients we've worked with, many have received tax refunds that far exceeded the cost of the tax points after purchasing additional tickets.

Tax Refund Benefits:100 million in refundable fundsAbout 10 million, Funds are repatriated through official channels, ensuring a fully compliant, closed-loop process across the entire chain.

② Duty-Free Shopping Without a Receipt + Hong Kong Companies Operating in Stores

Intended Audience:Sellers whose supply chains are unable to issue invoices or obtain special invoices

How to do it:VAT exemption policies apply to exports (no VAT is payable on exports, but no VAT refund is available either). At the same time, usingHong Kong Companies Setting Up Shop as Compliant Entities— Overseas companies receive foreign exchange directly through the platform; profits are retained overseas in compliance with regulations and repatriated to China as needed through service fees, trade markups, and other means.

Key Points:Although this approach doesn’t qualify for tax refunds, it at least aligns the ”store operations and foreign exchange receipts” and ”capital repatriation” processes, eliminating the need to operate without proper safeguards. With its simple corporate tax system and free foreign exchange policies, Hong Kong is the most commonly used offshore entity for cross-border sellers.

⚠️ Why It's Not Recommended to Insist on the 9610 Fixed-Rate Taxation Method

For cross-border e-commerce retail exports under Code 9610, there is a ”fixed-rate taxation” policy, according to4% Tax RatePaying corporate income tax. It sounds simple, but in practice, the barriers are quite high, the scope of application is limited, and enforcement standards vary by region. If your goods don’t fit the typical cross-border e-commerce retail small-package model, forcing them through the 9610 procedure could actually lead to problems. To determine whether this approach is right for you, we recommend a one-on-one assessment—don’t blindly apply it.

③ 1039 Market Procurement Trade Method

Intended Audience:Product categories included in the 1039 pilot program catalog, and the value per shipmentLess than $150,000, sellers who source their merchandise from small commodity markets

How to do it:The 1039 Market Procurement Trade Mode allows for ”export without invoices”; goods procured at designated markets in pilot areas (such as Huadu, Guangzhou) are exempt from VAT and do not qualify for a tax refund—no VAT is paid at the export stage, nor is a refund issued.

1,039 have specific requirements regarding product categories (primarily small commodities and daily necessities) and must source their goods from designated market clusters.If your product category falls under mainstream cross-border e-commerce categories such as 3C, apparel, or home goods, many of them are not included in the 1039 catalog and therefore do not qualify. As a result, this is not a one-size-fits-all solution for the vast majority of cross-border sellers; it is only suitable for specific sellers in specific categories.

When you compare the three options side by side, the best choice is obvious:

The selection logic is simple:

① The supplier can issue an invoice → Opt for Option 1 (Saiwei 2.0) to Maximize Tax Rebate Benefits

② The supply chain cannot issue an invoice → Go with Option 2 (Hong Kong entity) and at least streamline the foreign exchange receipts and repatriation process.

③ If the product category falls under the 1039 catalog → You can review Option 3

For the vast majority of sellers, either Option 1 or Option 2 will do the trick.

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04 A Real-Life Example: The Extra Money Spent on a Ticket Was Fully Refunded

Client Background:A seller in the home goods category in Foshan, with annual sales of approximately80 million....He had been sourcing goods from several local factories for a long time and had never asked for an invoice. When he found us,The total amount of taxes that could have been refunded over the three-year period exceeded 7 million...not a single cent has been refunded.

Concerns:The boss estimates that having the factory issue invoices would add 5–6 percentage points in taxes; for a business with a turnover of 80 million, the tax alone would amount toMore than 4 million,”What a rip-off.”

Our estimates:After purchasing a ticket, go to counter 0110 for a tax refund; 80 million is refundable.About 8 million; The cost of the tax surcharge is approximately4 million.;Net profit of approximately 4 million. At the same time, once the framework is compliant, there will be a solid basis for capital repatriation, bank risk control, and tax audits.

Results:The boss had us start building the framework that very day. Three months later, when the first tax refund came through, his exact words were: ”If I’d known I could get such a big refund, I’d have saved so much money over the past few years.”

That is why we have always emphasized—If you can issue an invoice, be sure to do so.. The tax rate may seem steep, but compared to the tax refund, it’s a drop in the bucket.

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📌 Is your tax refund being held up because you ”don’t have a receipt”?

Every seller’s situation is different—Can your supply chain issue invoices? What is your annual sales volume? What product categories do you sell? What export method are you currently using? The answers to these questions determine how much tax you can claim back and which compliance path you should take.

Not sure which path is right for you?

• New Sellers: Since sales haven't picked up yet, you can start with the tax-free option and set up the structure through a Hong Kong entity. Once sales reach a certain scale, you can switch to the retroactive tax refund process.
• Annual sales in the tens of millions during the growth phase: If the supply chain can cooperate, SAIWEI 2.0’s four-pillar framework can be implemented in one go, maximizing tax rebates and ensuring full compliance.
• A blockbuster with hundreds of millions in sales during its peak period: With multiple supply chains, platforms, and product categories, a customized architectural solution is needed to sort everything out one by one.