Cross-Border E-Commerce Tax Compliance: What Are the Advantages of the Saiwei 2.0 Model?
Published: July 24, 2026

Over the past few months, the most common inquiry we’ve received through our support system has been:“Is Savi 1.0 still usable? Should I upgrade to 2.0?”

The reason is that, starting last October, platforms such as Amazon began reporting sellers” revenue data to the tax authorities in accordance with Document No. 15. A large number of sellers operating multiple stores received text messages from the tax authorities stating, ”The sales revenue you reported does not match the data we have on file.”

The practice of ”zero reporting by individual stores and centralized tax refunds for export companies” under the SAIWEI 1.0 model now faces serious challenges in data reconciliation. It is against this backdrop that,Saiwei 2.0 Model (Overseas Procurement, Overseas Sales)It has been proposed by tax authorities in some regions as an optimization measure.

However, many sellers have only a superficial understanding of this model. Some say it’s the optimal solution, while others argue that the costs are too high. In today’s article, we’ll break down the advantages and trade-offs of Saiwei 2.0 once and for all, drawing on the latest tax authority guidelines and real-world case studies.

If you’re also in the cross-border e-commerce business and want to transition to compliance but aren’t sure how to proceed, feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat: jxhqcy890 / Mobile: 16625410105). Based on your specific situation, we’ll assign a professional consultant to address your concerns and provide one-on-one, end-to-end compliance solutions.

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01 Why is Savi 1.0 ”no longer enough”?

To understand the advantages of 2.0, you first need to figure out where the ”Achilles” heel” of 1.0 lies.

The classic architecture of Savi 1.0 is:N retail stores (registered in various cities) → 1 export company (centralized procurement, unified customs clearance) → 1 Hong Kong company (fund consolidation).

This structure has worked well over the past few years. The export company obtains input invoices, files customs declarations under code 0110 for exports, applies for tax refunds, and the Hong Kong company consolidates the proceeds—it all seems perfect.

Document No. 15 Changed the Rules of the Game::

🔴 Data Discrepancies: The company has consistently filed zero tax returns in the tax authority’s system, but the sales data Amazon reports to the tax authority amounts to hundreds of thousands or even millions each month—this ”discrepancy” directly triggers a tax alert.

🔴 Tax Base Disputes: Export companies in Shenzhen handle customs clearance and tax refunds centrally, but the local tax authorities in Dongguan and Changsha, where the retail companies are based, view this as ”tax revenue loss”—leading to a conflict over the attribution of tax revenue across regions.

🔴 Verification Pressure: Sellers in Shenzhen’s Longgang District, Guangzhou, Yiwu, and other locations have begun receiving the “Statistical Form on Cross-Border E-Commerce Multi-Store Models” issued by tax authorities, and the preliminary survey has already begun.

It is precisely under this threefold pressure that,Saiwei 2.0 was born out of necessity.

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02 How exactly does Savi 2.0 work?

The key change in Savi 2.0 can be summed up in just one sentence:Have a Hong Kong company act as an ”intermediary” to resell the goods, so that each store becomes a ”legitimate seller.”

It can be broken down into three parts:

Paragraph 1: Domestic export companies handle centralized procurement and customs clearance

The export company purchases goods from suppliers on a centralized basis (obtaining special VAT invoices), clears customs for export under the 0110 general trade category, and sells them to its own Hong Kong subsidiary. Ownership of the goods is transferred from the export company to the Hong Kong subsidiary, and the export company applies for a tax refund as usual.

Paragraph 2: Transfer of a Hong Kong Company to a Retail Company (Key Change)

The Hong Kong company then resells this batch of goods to various mainland retail companies. The Hong Kong company issues pro forma invoices to the retail companies, which serve as ”proof of overseas procurement costs” for the retail companies. It is recommended to use the cost-plus pricing method, with the markup generally kept between 3% and 10%.

Paragraph 3: The store sells to end consumers

The company sells goods to overseas consumers on the Amazon platform and recognizes revenue in accordance with the actual transaction amounts stated on the platform’s settlement statements.As a result, the revenue reported by the store matches the data submitted by the platform exactly, and the issue of data discrepancies is easily resolved.

To put it in the simplest terms:Saiwei 1.0 was about ”one export company handling everything,” while Saiwei 2.0 is about ”every store having its own legitimate purchase records and sales revenue,” with every transaction fully documented.

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03 Tax Treatment for SAIWEI 2.0: How Should Taxes Be Paid?

This is the issue sellers are most concerned about. Let’s break it down into two parts:

Value-Added Tax: Exempt

Since both the procurement (purchases from a Hong Kong-based company) and sales (sales to overseas consumers) by the store’s company take place overseas, and the goods do not enter the domestic market, the domestic VAT is exempted in accordance with Article 8 of the *Implementing Rules of the Provisional Regulations on Value-Added Tax*. However, it is recommended to file for a tax exemption for cross-border taxable activities with the competent tax authority in advance to mitigate tax-related risks.

Corporate Income Tax: Payed Locally

Each store company calculates and pays corporate income tax in accordance with its actual operating profit (revenue minus the Hong Kong company’s procurement costs and various platform fees) through normal accounting procedures at its place of registration.This resolves the issue of ”tax jurisdiction”—taxes are paid in the city where the business is located.

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04 The Four Key Advantages of Savi 2.0

Compared to Version 1.0 and other compliance solutions, the Version 2.0 model offers four unique advantages:

dominanceWhat Was Resolved?Why It Matters
"one" radical in Chinese characters (Kangxi radical 1)Eliminate Data DiscrepanciesStore-reported revenue = data submitted by the platform; this will no longer trigger a tax alert for ”discrepancies between reported and submitted data.” This is the most critical compliance requirement under Circular No. 15.
Balancing the Allocation of Tax RevenuesEach company pays taxes independently at its place of registration, thereby resolving the tax base dispute regarding ”Shenzhen-based export companies monopolizing tax rebates and companies with out-of-town stores making zero contribution.”
surname SanHigh Compliance and StabilitySome tax authorities have explicitly recognized the business logic of the 2.0 model. It is a ”substance-over-form” approach within the framework of current tax law and is more likely to withstand audits than the pure aggregation model.
Provide documentation of overseas procurement costsThe pro forma invoices issued by the Hong Kong company provide the retail company with legitimate ”proof of overseas procurement costs,” enabling the retail company to calculate its profits based on documented evidence.

👉Add Qicaiying’s online customer service (WeChat: jxhqcy890 / Mobile: 16625410105) to receive the following for free: a one-on-one compliance path assessment + a comparison of Saiwei 1.0, 2.0, and 9810 solutions + a customized implementation timeline. Please include ”Compliance Plan” in the message for priority processing! We’ll assign a professional consultant to answer your questions and provide one-on-one service for a full-process compliance solution.

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05 Saiwei 1.0 vs. 2.0: What's the Difference?

comparison dimensionSaiwei 1.0 (Pooling Model)Saiwei 2.0 (Overseas Sourcing and Overseas Sales)
Store and Company Registrationzero declarationRevenue is recognized based on the platform’s actual transaction volume
Data ComparisonSignificant discrepancies have been detected, triggering an alert"Declaration" = "Submission"; there is no difference.
Tax Base AttributionConcentrated in the location of the export companyEach store is registered as a separate entity and pays taxes independently.
The Role of Hong Kong CompaniesFor fund consolidation onlyFund Consolidation + Transshipment of Goods + Invoicing
Funds ControlFunds 100% in the account under the actual control of the bossFunds are spread across the accounts of various store companies
Financial WorkloadCentralized processing, low complexityEach store keeps its own separate books and files its own tax returns, which doubles the workload.

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06 Which sellers are a good fit for Saiwei 2.0?

Version 2.0 isn't right for everyone, but we strongly recommend that the following three types of sellers give it serious consideration:

Seller TypeWhy It's a Good Fit
Sellers Who Have Received Tax AlertsThe tax authorities have already noticed the discrepancies in your data. Rather than passively waiting for an audit, it’s better to take the initiative and use Version 2.0 to ensure your data matches up.
Medium-sized sellers with 5–20 storesThe financial workload is manageable, the risk associated with the dispersion of funds is controllable, and the company is well-suited for a comprehensive transformation.
Sellers whose store companies are registered under their own namesThe legal representative of the store is either the owner or a close relative, so there is no risk of a nominee holding the shares, and the security of funds is guaranteed.

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07 Four-Step Plan for Implementing SAIWEI 2.0

If you decide to go with Version 2.0, the following four steps are the most critical milestones:

moveWhat to DoKey reminders
1Establishing a Complete Chain of EvidenceProcurement agreements, payment records, pro forma invoices, shipping documents, FBA inventory records, and declarations of transfer of title between the store’s company and the Hong Kong company—not a single one can be missing.
2Communicate with the Tax Authority FirstRegarding the compliance of pro forma invoices as tax-deductible expenses for corporate income tax purposes, it is essential to consult with the competent tax authority in advance and seek their approval.
3Reasonable and Justifiable PricingFor the resale of a Hong Kong company, it is recommended to apply a cost-plus markup of 3%-10%. Consult with the tax authorities in advance to confirm the reasonableness of the pricing and avoid being deemed to be transferring profits.
4The Unity of the Three Flows Is IndispensableBusiness flows (purchasing → resale → retail), cash flows (receipts → payments → settlement), and invoice flows (pro forma invoices → posting → filing) must correspond one-to-one.

👉Add Qicaiying’s online customer service (WeChat: jxhqcy890 / Mobile: 16625410105) to receive the following for free: a one-on-one compliance path assessment + a comparison of Saiwei 1.0, 2.0, and 9810 solutions + a customized implementation timeline. Please include ”Compliance Plan” in the message for priority processing! We’ll assign a professional consultant to answer your questions and provide one-on-one service for a full-process compliance solution.

扫码添加企财盈在线客服

Tags:
  • Platform Data Reporting
  • Cross-border taxation
  • Saiwei 2.0
  • E-commerce Tax Compliance
  • Cross-Border E-Commerce Taxation
  • tax risk
  • Communication with the Tax Authority
  • Chain of Evidence
  • Safeway model
  • Amazon seller
  • export tax rebate
  • Financial and Tax Compliance
  • Hong Kong company
  • cross-border e-commerce