You've been selling on Amazon for several years, and you've always had the freight forwarder handle the export clearance. The customs declaration lists the freight forwarder's name—it has nothing to do with you.

You'll find it hassle-free. No need to learn customs clearance procedures or deal with paperwork.

By the end of 2025, freight forwarders will tell you: You can no longer issue invoices. Circular No. 17 requires reporting the actual principal’s information; if this information cannot be provided, the freight forwarder will be liable for corporate income tax.

You suddenly realize there's a problem—

In customs records, the “consignor” is the freight forwarding company, while in the platform’s sales records, the “seller” is you. Previously, these two sets of data were not interconnected, but they have been linked since 2026.

If the tax authorities combine the two sets of data, how will you prove that those goods belong to you?

Your company has never reported a single penny in export revenue on its books.

If your company has a long history of export transactions but you're unsure of the level of risk involved, you can start by scanning the QR code.Add me on WeChat: qcygscszk, with the note “Purchase Order Export Assessment,” to help you quickly assess the risk level.

01 Why was it fine before?(math.) genusIs something wrong now?

Previous Environment: The reason the "buy-and-ship" export method works is because the data isn’t shared. The platform doesn’t know exactly what goods you’re shipping, customs doesn’t know who the actual owner of the goods is, and the tax authority doesn’t know how much you’ve been paid. Each agency operates in isolation, and no one can connect the dots.

Change No. 1: Announcement No. 17 has cut off the buying channel.

On July 7, 2025, the State Taxation Administration issued the “Announcement on Optimizing Matters Related to Corporate Income Tax Advance Payment Filings” (No. 17 of 2025), stipulating that, effective October 1, 2025, enterprises that export goods through agents (including market procurement trade and comprehensive foreign trade services) must simultaneously submit basic information on the actual commissioning party and the export value when filing advance tax returns. The actual commissioning party refers to the entity that actually manufactures and sells the exported goods.

The announcement introduced “penetrative” information verification for the first time in the corporate income tax prepayment process, thereby completely eliminating the gray area that previously existed in the agency export process—where contracts were subcontracted through multiple layers and the actual cargo owners remained unaccounted for in tax filings.

Change No. 2: Integration of customs and tax data.

Starting in 2026, customs and tax authorities will implement electronic data verification through an integrated network. The platform will automatically compare the sales figures you report, the export value recorded by customs, and the tax return data received by the tax bureau—all three sets of data will be automatically cross-checked. The detection rate for fraudulent export transactions is 100%.

Have an impact: Following the implementation of Announcement No. 17, the traditional “invoice-purchasing export” model (where there is no actual owner of the goods or the actual manufacturer is concealed) is no longer viable. Freight forwarders are no longer willing to accept invoice-purchasing business. If a company fails to accurately report the information of the actual party commissioning the export, the transaction shall be treated as self-operated, and the company shall be responsible for declaring and paying the corporate income tax corresponding to the export amount. Several cross-border e-commerce enterprises in Longhua, Shenzhen, have already received “Notices of Investigation into Risk Issues” from the tax authorities, requiring them to submit a complete set of business, financial, and tax records within the specified timeframe.

02 What are the risks involved in export transactions where the buyer pays?

Sellers with a long history of export transactions are currently facing three key challenges:

First, revenue and costs do not match, posing a risk of having to pay back taxes as if the sales were domestic.

Your store has sales revenue, but there are no corresponding export customs declaration records in the company’s books. You have never reported the revenue from export sales made through third-party fulfillment. After the platform submitted its data, the tax authorities are now aware of your revenue, but you have no corresponding export records—which is essentially telling the tax authorities that you are concealing income.

According to Document No. 39 [2012] of the Ministry of Finance and the State Administration of Taxation Announcement No. 24 [2012], export revenue from “buy-side” transactions is treated as domestic sales for tax purposes and is not eligible for export tax rebates or exemptions. Failure to file export declarations in compliance with regulations may result in such revenue being treated as domestic sales, leading to the collection of additional value-added tax.

Second, historical purchase records can be traced.

Many sellers believe that “past transactions cannot be traced.” However, the retention period for export tax rebate filing documents is as long as 10 years. Although past “purchased-invoice” exports may not be traceable now, once the data is integrated in 2026, the tax system will be able to retroactively calculate your export volume based on platform data and then cross-reference it with customs declarations—any discrepancies will indicate “purchased-invoice” exports.

Third, if you are investigated, the costs will be extremely high.

Let's do the math: With annual sales of 100 million, if caught, the company will have to foot the bill for exports:

• Corporate Income Tax Back Payment: Calculated based on a gross profit margin of 30%, approximately 7.5 million
• Late payment penalty (based on 3 years, annualized at 18.25%): approximately 4.1 million
• Fine (at 0.5 times the base amount): approximately 3.75 million

Total: Over 15 million.

real case: In January 2025, the First Audit Bureau of the Shenzhen Municipal Taxation Bureau investigated a case involving a syndicate that issued fraudulent invoices to defraud tax authorities. The syndicate controlled multiple companies to fraudulently obtain export tax rebates; the bureau recovered taxes and imposed fines totaling 60.1192 million yuan. Three companies, including Shenzhen Zhongxingwang Trading Co., Ltd., engaged in fraudulent exports through methods such as “purchasing invoices to match shipments,” defrauding the government of 6.3101 million yuan in export tax rebates. Ultimately, they were ordered to pay back taxes and fines totaling 12.3055 million yuan.

03 How can "buy-and-ship" exports be converted to formal exports?

To transition from "buy-and-ship" exports to formal exports, we recommend proceeding in the following three steps:

Step 1: Thoroughly review historical purchase records.

Compile a list of goods exported via freight forwarders over the past three years, along with customs declaration numbers, logistics documents, and payment records—to determine which goods were shipped on account, their total value, and which platform’s sales they correspond to.

This step is not intended as a “voluntary disclosure,” but rather to assess the extent of risk exposure—identifying the years with the highest risk and the business lines with the largest amounts, and addressing them first.

Step 2: Select a compliant export model based on the type of business.

When it comes to formalizing export transactions, there is no “one-size-fits-all” solution. Different business models require different export pathways:

• VAT special invoices are available → By using the self-declaration model, you can apply for export tax rebates
• I can only get a general admission ticket → Adopt a model of duty-free shopping at the exit without tax refunds
• I can't get any receipts → Use the 1039 Market Procurement Trade Model

Specifically regarding the selection of regulatory codes:

• Using FBA, with special invoices, and high-value goods → Route 9810 (Overseas Warehouse Export) , You can claim a tax refund as soon as the goods leave the country.
• Engaged in B2B bulk exports, with special invoices and import/export rights → Route 0110 (General Trade) , the highest tax refund rate
• Operating a small direct-to-consumer business, unable to obtain special invoices, registered in the Comprehensive Pilot Zone → Take Route 9610 (Retail Export) , and are eligible for duty-free shopping without a receipt
• Closing deals on a B2B platform, shipping from overseas warehouses → Take the 9710, and enjoy simplified reporting

Step 3: Establish a new export process.

• Apply for Import and Export Rights: Go to the Commerce Bureau, Customs, and the State Administration of Foreign Exchange to complete the filing process
• Choosing a Compliant Freight Forwarder: Find a freight forwarder that can comply with the requirements of Document No. 17 and report accurate information about the actual principal.
• Establishing a Document Chain: Purchase Contract → Export Customs Declaration → Shipping Documents → Foreign Exchange Receipt Records, forming a complete closed-loop process

Following the implementation of Document No. 17, sellers can use the accurate information reported by compliant freight forwarders to prove ownership of exported goods and legally record the cost of those goods in the company’s accounts.

If your company has a long history of export transactions but isn’t sure where to start with the transition, please contact our customer service team.WeChat: qcygscszk, with the note “Transition to export-oriented business.” We’ll help you with two things:

• First, assess the extent of the risk exposure from past export orders and identify which year is the most urgent;
• Second, we recommend the most suitable compliance export route based on your business model.

04 What can Qi Cai Ying do for you?

Qicaiying has extensive practical experience in helping businesses transition from export-based invoicing to compliance, and can assist you by:

① Risk Assessment of Historical Transaction Records
Review your past export data, logistics records, and payment documentation to assess the magnitude and priority of potential tax liability risks.

② Recommendations for Selecting an Export Model
Based on your business type (B2B/B2C/FBA), invoicing details, and warehousing method, we recommend the optimal export control code.

③ Obtaining Import and Export Rights and Establishing the Process
Assist in completing the filing requirements with the Commerce Bureau, Customs, and the Foreign Exchange Administration, and establish a comprehensive documentation process covering “procurement—customs clearance—export—receipt of foreign exchange.”

If you're struggling with export invoicing and aren't sure where to start, 📱 WeChat: qcygscszk📞 Phone: 18676749275

Under the heading “Transitioning to Export-Oriented Business,” we'll help you make sense of it all.