The prospectuses of publicly traded companies hold the key to understanding the structure of cross-border e-commerce. GreenLink Technology and Saisi Times—major cross-border e-commerce players with annual revenues in the billions—why did they both choose to establish companies in Hong Kong? Was it merely for ”tax avoidance”? If it were just about tax avoidance, how were they able to successfully pass the listing review, receive export tax rebates, clear the CSRC’s scrutiny, and ultimately go public? Today, we’ll useActual Data from the Prospectus...let's break down this architecture in detail.

If you have any questions regarding financial and tax compliance...If you have any questions, feel free to add our Qicaiying customer service WeChat account for assistance.(WeChat: jxhqcy890 / Mobile: 16625410105)

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01 Saiwei Times: 708 Stores + Lanmat’s Four-Tier Structure in Hong Kong

Saiwei Times' prospectus reveals that as of 2024, the company owns708 stores... distributed across platforms such as Amazon, Wish, eBay, and Walmart. A four-tier architecture underpins this scale.

First Level: Retail Companies.Saiwei’s 708 stores are registered under multiple separate entities. Why not operate multiple stores under a single company? Because Amazon poses a risk of account association—if one store runs into trouble, all associated accounts will be suspended. Spreading operations across multiple entities is a fundamental practice.

Second Tier: Domestic Operating Companies.Saiwei has several operating companies in Shenzhen, Changsha, Dongguan, and other locations, which are responsible for product selection, operations, and supply chain management. These companies charge service fees to the store operators, serving as the first stop for the repatriation of domestic profits.

Third Tier: Procurement and Export Companies.Responsible for purchasing goods from domestic suppliers and handling export customs clearance procedures. After the domestic company makes the purchase, the goods are exported to the Hong Kong company or an overseas warehouse under the 0110 general trade or 9610 cross-border e-commerce modes, and an export tax refund is applied for.

Fourth Tier: Hong Kong Companies.Hong Kong Lanmate, as a representative example, serves as the core profit center and funding pool for the entire model. It purchases goods from domestic suppliers and resells them to overseas consumers; all overseas sales revenue is ultimately remitted to the Hong Kong company’s account.

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02 Hong Kong Companies: Why Are They a ”Best-Selling Standard”?

It’s no coincidence that major retailers choose Hong Kong companies as their offshore entities. Here are four key reasons:

Compared to the domestic market:Taking cross-border e-commerce profits as an example, if they were all recorded in the domestic company’s books—corporate income tax at 25% + value-added tax at 13% (with an even higher effective tax rate if input tax credits are insufficient) + individual income tax on dividends at 20%—the combined tax burden would easily exceed40%. As for the tax burden under the Hong Kong company structure: the first 2 million in profits8.25%, the excess amount16.5%, and there are no turnover taxes.

But that's not the most important point. The true value of a Hong Kong company lies in the fact that it is part of the entire closed-loop cross-border transaction process:“Hub”—When a domestic procurement company sells goods to a Hong Kong company, it constitutes a compliant B2B cross-border transaction, and the company is eligible to apply for an export tax rebate; when the Hong Kong company then resells the goods to a retail company, the retail company obtains valid documentation of its procurement costs and can recognize revenue based on actual sales—thus completing the entire process.

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03 Lulian Technology: A Growth Curve Showing Overseas Revenue Doubling Over Three Years

If the Suntech era represented the pinnacle of the ”multi-store” model, then Greenconn Technology (301606.SZ) exemplifies the textbook example of the ”brand globalization” model.
Lianli Technology listed on the ChiNext board of the A-share market in July 2024 and submitted a prospectus to the Hong Kong Stock Exchange in February 2026, intending to list on the Hong Kong Main Board. The key figures disclosed in its prospectus are as follows:
GreenLink Technology’s prospectus also disclosed details regarding the use of a two-tier structure. Its overseas revenue from 20232.4 billion→In 2024,3.512 billion→For the first three quarters of 2025,3.789 billion, with annual growth rates of46.5%respond in singing56.3%(Annualized).

GreenLink’s approach differs from Suntech’s, but the core logic is the same:Hong Kong is the first stop on the road to globalization.Hong Kong companies serve as a hub, sourcing goods from the mainland and then distributing them to subsidiaries in various regions. This approach allows companies to take advantage of Hong Kong’s tax benefits while enabling localized operations through their regional subsidiaries.
Without Hong Kong companies serving as a ”transit point,” this growth curve would be difficult to achieve.

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04 Can Regular Sellers Use This Framework? A Simplified Version of the Saiwei Model 2.0

After reviewing the structure of publicly traded companies, many sellers might think: “That’s how the big players operate—I don’t need that for a business with a turnover of a few hundred million, do I?”

Actually, that’s not the case. The core logic is the same; it’s just a matter of scale. Within the industry, this architecture is simplified and referred to as“Saiwei 2.0 Model”...at the core of which is a closed-loop cross-border transaction model involving ”domestic procurement—resale in Hong Kong—retail sales at domestic stores”:

This model solvesThree Core Issues::

First, the data matches up.The store’s company recognizes revenue based on the actual transaction amount recorded in the platform’s backend, which matches the data the platform reports to the tax authorities, eliminating the risk of data discrepancies.

Second, the tax base is acceptable.Each store or company pays corporate income tax at its place of registration based on its actual operating profit, thereby resolving disputes over the attribution of tax revenue from other locations.

Third, you can get a tax refund.Domestic export companies that conduct centralized procurement and then declare exports under the "0110" general trade category can apply for export tax rebates as usual.

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05 Three Common Misconceptions About Setting Up a Savi Architecture

⚠ Misconception #1: ”All you need to do is register a Hong Kong company.”

A Hong Kong company is merely an overseas entity; it does not automatically mean compliance. Without a corresponding domestic export company, a compliant procurement chain, and ODI filing—funds in the Hong Kong account cannot be repatriated, and the structure is hollow.

⚠ Misconception #2: ”Once the architecture is in place, you can rest easy.”

Now that the framework is in place, we must perform the monthly ”four-stream reconciliation.” The flow of goods, invoices, funds, and contracts—if even one of them doesn’t match up, we won’t be able to explain it to the tax authorities.

⚠ Misconception 3: ”Small sellers don’t need to make things this complicated.”

For annual sales under 5 million, the 9610/9710 model might work. But once sales exceed 10 million, there’s no escaping the data cross-checks under Phase IV of the Golden Tax System. The sooner you set up the framework, the lighter your historical burden will be.

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06 put at the end

The structure of a Hong Kong company paired with a mainland store is not exclusive to major retailers. Essentially, it uses a compliant offshore entity to address the core issue of cross-border e-commerce: ”receiving payments overseas → repatriating funds to the mainland.”

The architecture itself isn’t the hardest part; the real challenges lie in three areas: whether supplier input invoices can be processed in a timely manner, whether ODI registration can be approved, and whether the daily ”four-stream alignment” can be successfully implemented.

If your store’s monthly sales have already exceeded 1 million, we recommend that you start learning about business structures now. Want to know how to structure your store? The Qicaiying Tax and Compliance Team offers business structure diagnostic services and tailors compliance solutions based on the number of stores you operate, your procurement model, and your profit scale.

Compliance comes at a cost, but the price of operating without it is even higher.Compliance transition is better sooner rather than later, the earlier the layout, the lower the cost, the more stable the development.

📌 If your business is in one of the following stages:

• [Start-up period] Annual revenue < 20 million: Worried about the impact of zero filing, private collection, and Golden Tax Phase IV?
• [Development Period] Annual revenue 20 million-100 million: troubled by export tax rebates, multiple private accounts, financial chaos?
• [Maturity] Annual revenue > 100 million: thinking about equity design, inventory optimization, IPO readiness?

We have the right solutions and practical experience for all of these situations. If you haveHong Kong Company Registration, Bank Account Opening, Annual Audit, Financial and Tax Compliance, and Setting Up Structures for Import and Export Operationsand other needs.Sellers who require a case-by-case assessment based on the number of stores, sales volume, supply chain conditions, and existing business entities, you can contact Qicaiying’s online customer service (WeChat ID:jxhqcy890 / Mobile: 16625410105). When communicating with us, we recommend that you first prepare basic information regarding the platform, the entity, procurement, exports, and payment collection. Based on this information, we will arrange for a professional manager to provide tailored answers to your questions.