For cross-border sellers who are sensitive to cash flow, a new policy can directly improve capital turnover efficiency: the ”Tax Rebate Upon Departure” policy under the 9810 overseas warehouse export model has officially taken effect. This means that export tax rebates can be applied for as soon as goods clear customs and leave the country, without having to wait for actual sales overseas to be completed—the tax rebate waiting period, which used to last several months or even a year, has been reduced to a matter of weeks. The accelerated cash flow is changing the operational rhythm of cross-border e-commerce.

The value of this policy becomes even clearer when viewed through a set of data. Previously, for goods exported using the 9810 overseas warehouse model, companies had to wait until the goods were actually sold at the overseas warehouse before they could apply for a tax refund using sales receipts; the entire process typically took between 4 and 12 months, depending on the sales pace. For many small and medium-sized sellers, tax refunds were often stuck in the process for extended periods, becoming ”paper profits” that were neither visible nor tangible. However, with the implementation of the ”Tax Refund Upon Departure” policy, as long as goods have completed customs clearance and departure procedures, companies can apply for a tax refund from the tax authorities using the customs declaration form. The time it takes for refund funds to be credited has been shortened to 1 to 2 months—for a seller with annual exports of 50 million yuan, this means that several million yuan in working capital is released ahead of schedule.

More importantly, this is not an isolated measure to streamline tax refunds, but rather a core component of a comprehensive set of policies for cross-border e-commerce exports. From raising the single-declaration limit for the 9610 procedure to the full implementation of cross-customs district returns, and from standardizing foreign exchange collection deadlines to linking tax and foreign exchange data for verification, the overall direction of these policies is very clear: to enable compliant sellers to receive their funds faster and streamline their processes, while simultaneously forcing non-compliant parties out of the gray area.

As new policies on export tax rebates for cross-border e-commerce are being rolled out in rapid succession, companies urgently need to establish their tax rebate compliance systems in advance. Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and other locations, as well as annual review and auditing, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong residency application, renewal, and permanent residency services; Singapore EP application services; as well as one-stop services such as cross-border e-commerce mentoring and agency operations. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

I. The Core Mechanism of ”Tax Refund Upon Departure”: Tax Refund First, Settlement Later

To understand the ”Tax Refund upon Departure” policy for 9810, it is essential to first clarify its fundamental differences from previous tax refund models.

Previous model: Purchase first, return later—a lengthy process. Under the 9810 cross-border e-commerce overseas warehouse export model, goods are first cleared through customs for export to an overseas warehouse and then sold on a per-order basis on overseas e-commerce platforms (such as Amazon, eBay, etc.). To apply for a tax refund, businesses must first obtain proof of actual sales—specifically, platform sales data, overseas warehouse shipment records, and end-consumer delivery confirmation. For many sellers, it can take half a year or even longer for a batch of goods to be cleared through customs and sold out completely. Since applying for a tax refund requires collecting and organizing a large volume of overseas sales documentation, the entire process is often delayed until the following year. Many small and medium-sized sellers simply give up on tax refunds due to the difficulty of collecting documentation and the complexity of the process, which is tantamount to needlessly handing over tax refunds that should have been returned to them to the government.

New Model: Refund upon Departure, Post-Sale Settlement. “The core innovation of the ”Tax Rebate upon Departure” program lies in its two-step mechanism of ”rebate first, settlement later.” In the first step, once customs clearance procedures for the goods” departure have been completed, enterprises can apply to the tax authorities for an export tax rebate based on supporting documents such as the export goods customs declaration form and overseas warehouse booking confirmation—without having to wait for the actual sale to be completed. In the second step, after the goods are actually sold from the overseas warehouse, the enterprise must reconcile the actual sales figures with the tax refund amount already received—any overpayment must be repaid, and any underpayment can be claimed through a supplementary application. This mechanism shifts the timing of the tax refund from ”after the sale” to “upon departure,” significantly shortening the seller’s capital tie-up period.

9610 Synchronized Positive Development: The limit for a single filing has doubled. Along with the implementation of the 9810 “Tax Refund upon Departure” policy, significant adjustments have also been made to the 9610 cross-border e-commerce retail export model—the single-declaration limit has been raised from 5,000 RMB to 10,000 RMB. The 9610 model applies to direct-mail small-package exports. Doubling the per-declaration limit means that a large number of small packages—which previously had to go through general trade customs clearance due to exceeding the value threshold—can now use the 9610 simplified declaration channel, resulting in reduced customs clearance costs and processing times. For independent e-commerce sellers and small-package sellers whose primary business model relies on direct mail, the burden-reducing effects of this adjustment are immediately apparent.

II. Standardization of Cross-Customs District Returns and Foreign Exchange Time Limits: The Synergistic Effects of a Comprehensive Policy Package

“The ”Tax Refund Upon Departure” policy is not a standalone initiative; it creates a clear synergistic effect when combined with two other policies—the nationwide implementation of cross-customs district returns and the standardization of foreign exchange collection deadlines.

Cross-customs-district returns are now implemented nationwide. Previously, returned cross-border e-commerce export goods could only be processed at the original port of export. If a seller cleared customs in Shenzhen but returned the goods via Shanghai, they had to coordinate across customs districts, which was a cumbersome process. Following the implementation of the new policy, companies can now process returns for cross-border e-commerce export goods at any port nationwide, and returned goods are exempt from import duties, value-added tax (VAT), and consumption tax (effective through the end of 2027). This is particularly significant for the overseas warehouse model—when unsold goods are returned, sellers are no longer ”tied” to the original port, and both the logistics costs and operational complexity of returns are significantly reduced.

The deadline for foreign exchange receipts has been standardized as April 30 of the following year. Previously, the deadline for cross-border e-commerce enterprises to receive foreign exchange varied by region; some areas required payments to be received by December 31 of the same year, while others extended the deadline to March 31 of the following year. This lack of uniformity led to a mismatch between the timing of foreign exchange settlement and tax refund filing for a large number of enterprises. The new policy standardizes the deadline for foreign exchange collection under cross-border e-commerce exports to April 30 of the following year. This adjustment gives companies more time to align the timing of platform payments, foreign exchange settlement, and tax refund filings.

Online verification of tax and foreign exchange data. This is the ”data foundation” underpinning the entire policy package. The tax authorities’ export tax rebate data is now linked to the foreign exchange authorities’ foreign exchange receipts data for cross-checking—the system automatically compares the amounts reported in export tax rebate declarations with the actual foreign exchange receipts. If the amounts match, the transaction is cleared normally; if they do not, the system automatically flags it as a warning. This means that sellers must ensure data consistency across both export tax rebate declarations and foreign exchange receipts; otherwise, tax rebates may be suspended and foreign exchange transactions may be subject to scrutiny.

In response to the growing needs of cross-border e-commerce sellers regarding export tax rebates and foreign exchange compliance, Qicaiying has launched a combined service package titled ”E-commerce Compliance Accounting + Bookkeeping and Tax Filing”: E-commerce Compliance Accounting covers the organization of platform transaction records, the matching of order data with customs declaration data, the alignment of payment receipts with foreign exchange receipt criteria, and the review of tax rebate filing documents; The Bookkeeping and Tax Filing service ensures that accounts are maintained in accordance with regulations from the outset and that all tax types are filed accurately, providing the underlying data support necessary for export tax rebates. Qicaiying Group specializes in providing company registration services for domestic and international entities in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), and the Cayman Islands, as well as corporate annual review and audit, bookkeeping and tax filing, tax compliance, information changes, bank account opening, ODI and FDI filings, as well as Hong Kong residency applications, renewals, and permanent residency services; Singapore Employment Pass (EP) application services; and cross-border e-commerce mentoring and agency services. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

III. High-Risk Categories 3 and 4 and Filing Requirements: Dividends Aren’t ”Free Money”

“Tax Refund Upon Departure” is indeed a tangible policy benefit, but this benefit doesn’t come for free—the tax authorities have also identified four types of high-risk scenarios and established strict filing requirements, meaning businesses must operate within the compliance framework to qualify.

Four Types of High-Risk Scenarios:

First, confusion over policy classifications. Some companies mix the use of the 9810 code (cross-border e-commerce exports via overseas warehouses) with general trade exports and processing trade exports on their customs declarations, leading to confusion regarding the criteria for tax refunds. The 9810 code has its own regulatory code and tax refund logic and must not be used interchangeably with customs declarations for other trade modes.

Second, fraudulent overseas consumption. After goods are cleared through customs and shipped overseas, they are not actually stored or sold in overseas warehouses but are instead used in ”empty-run” schemes to fraudulently claim tax refunds. This is a practice that has become a key target for enforcement since the integration of tax and customs data—with cross-verification of customs logistics tracking data, overseas warehouse inventory records, and e-commerce platform sales data, ”empty-run” schemes are virtually impossible to conceal.

Third, the commingling of processing trade accounts. During the validity period of their processing trade manuals, some enterprises declare goods that should be managed as processing trade under tariff code 9810 for export and apply for tax refunds, resulting in double tax refunds or the commingling of regulatory rules.

Fourth, operational errors during the transition period. In the early stages of policy implementation, some enterprises experienced discrepancies in their reporting criteria during system migration and document adjustments—such as inconsistencies between the customs declaration amount and the invoice amount, or failure to promptly update overseas warehouse registration information. Although these non-willful discrepancies pose a relatively low risk, failure to correct them in a timely manner may still result in the suspension of tax refunds.

Filing Requirements: Three types of core documents. To take advantage of the 9810 tax refund upon departure policy, companies must complete the overseas warehouse registration process. The key documents include: First, the overseas warehouse booking confirmation—which proves that the goods have actually been arranged for storage; second, proof of ownership or tenancy for the overseas warehouse—for company-owned warehouses, a property title or lease agreement must be provided, while for third-party warehouses, a warehousing service contract must be submitted; third, the overseas warehouse lease agreement—for leased warehouses, a formal lease contract with the warehouse operator must be provided. All three types of documents are mandatory, and the information must match the data on the customs declaration form.

IV. Conclusion: In an Era of Accelerated Tax Refunds, Compliance Equals Capital Efficiency

The implementation of the ”9810 ”Tax Refund Upon Departure”” system marks the transition of cross-border e-commerce export tax refunds from an era of ”slow waiting” to an era of “rapid processing.” For sellers, this is not merely a numerical change in the time it takes for tax refunds to be credited to their accounts; it represents a qualitative leap in capital utilization efficiency—receiving tax refunds months in advance means more flexible inventory planning cycles, greater confidence in preparing for peak seasons, and a stronger safety margin for cash flow.

However, there is one prerequisite for realizing these benefits: compliance. From the registration of overseas warehouses to the consistency of documentation, and from tax refund filings to the reconciliation of foreign exchange receipts, every step requires professional and standardized handling. Given the interconnected verification of tax and foreign exchange data, any discrepancy in the data at any stage could result in the suspension of tax refunds or a reduction in the benefits received.

The window of opportunity is closing—only by planning ahead can you turn a reactive situation into a proactive one. Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and more, as well as corporate annual reviews and audits, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI and FDI filings, and other corporate services; Hong Kong residency applications, renewals, and permanent residency services; Singapore Employment Pass (EP) application services; and cross-border e-commerce mentoring and managed operations—all as part of our one-stop service. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

At a time when profit margins in cross-border e-commerce are becoming increasingly slim, export tax rebates represent a ”hidden profit” that cannot be overlooked. Streamlining the tax rebate process and establishing a solid foundation for compliance—so that policy benefits are truly converted into cash flow in a company’s accounts—is the best reward this round of policies offers to sellers who take their business seriously.