“How can I claim an export tax refund if I don’t have a purchase invoice?” This is one of the most common questions asked by cross-border e-commerce sellers. Many sellers source goods from 1688, retail stalls, and factory outlets, where suppliers are unable to provide special VAT invoices, making it impossible to follow the standard tax refund process after export. In fact, however, the government has long established a compliant tax-exemption channel for such sellers—the ”invoice-free tax exemption” policy in comprehensive pilot zones. According to Announcement No. 36 of 2019 issued by the State Taxation Administration and subsequent policy extensions, e-commerce export enterprises registered in comprehensive pilot zones may enjoy VAT and consumption tax exemptions for goods exported without valid purchase documentation. By 2026, with cross-border e-commerce pilot zones covering 165 cities nationwide, this policy has become a core compliance tool for sellers making “invoice-free” purchases. However, in practice, a large number of sellers are still unable to enjoy the benefits of this tax exemption—and even face tax risks—due to failure to meet eligibility requirements, non-compliant registration, or untimely filing.

The core value of the tax-exemption policy for purchases without invoices lies in the fact that it moves sellers making such purchases out of the ”gray area” and into the ”compliant channel,” thereby not only exempting them from VAT and consumption tax but also helping them avoid the risk of being deemed to have evaded or underpaid taxes due to purchases made without invoices. 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 company reviews, audits, bookkeeping, tax filing, tax compliance, business registration changes, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong residency application, renewal, and permanent residency services; Singapore Employment Pass (EP) application services; and cross-border e-commerce mentoring and agency 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).

I. Policy Framework: What Is ”Tax Exemption Without a Tax Invoice”?”

“The full name of the ”tax-free without an invoice” policy is the ”Tax-Exemption Policy for Retail Export Goods in Comprehensive Cross-Border E-Commerce Pilot Zones.” Its legal basis is the “Notice on Tax Policies for Retail Export Goods in Comprehensive Cross-Border E-Commerce Pilot Zones” (Cai Shui [2018] No. 103) issued by the Ministry of Finance and the State Taxation Administration in 2019, as well as subsequent extension documents.

Core rules: E-commerce export enterprises registered within the Comprehensive Pilot Zone that sell goods to overseas consumers through e-commerce platforms are eligible for VAT and consumption tax exemptions if they do not have valid purchase documentation.

The fundamental difference from export tax rebates: To claim an export tax refund, a company must obtain a special VAT invoice (input invoice) and, in accordance with the ”exemption and refund” or ”exemption, offset, and refund” methods, receive a refund for the VAT already paid at the domestic stage. In contrast, the ”invoice-free tax exemption” does not require a purchase invoice; instead, VAT and consumption tax at the export stage are directly exempted. The relationship between the two is “complementary rather than mutually exclusive”—invoiced exports follow the tax rebate process, while non-invoiced exports follow the tax exemption process.

Policy Continuity: At the end of 2025, the Ministry of Finance and the State Taxation Administration issued a notice extending the tax-exemption policy for retail export goods in comprehensive pilot zones. This means that, for the foreseeable future, the “invoice-free” tax-exemption policy will continue to serve as a core institutional arrangement for cross-border e-commerce compliance.

II. Three Key Conditions: All Must Be Met

Although the threshold for the tax-free policy without invoices is lower than that for export tax rebates, it is not a matter of ”registering and automatically qualifying.” Enterprises must meet all three of the following conditions.

Condition 1: Registration in the Comprehensive Pilot Zone. Companies must be registered within a Comprehensive Cross-Border E-Commerce Pilot Zone approved by the State Council. As of 2026, there are 165 such pilot zones nationwide, covering all provincial capitals and most prefecture-level cities, providing companies with a wide range of options for their registered location. It is particularly important to note that the enterprise’s registered address must be within the policy coverage area of the pilot zone, rather than simply ”registered in the city where the pilot zone is located.” In some cities, the coverage of the pilot zone may be limited to specific areas; therefore, enterprises must confirm whether their registered address falls within the defined boundaries of the pilot zone before registration.

Condition 2: Registration on an online platform. Businesses must complete merchant registration on e-commerce platforms and transmit electronic information regarding transactions, payments, and logistics to customs through these platforms. This means that businesses must conduct sales through official cross-border e-commerce platforms (such as Amazon, eBay, Shopee, AliExpress, etc.) or through their own independent websites (which must be integrated with customs systems). Non-platform channels, such as offline trade and mail parcels, are not eligible for the tax-exemption policy for transactions without invoices.

Condition 3: Electronic customs declaration. Enterprises exporting goods must file electronic declarations using the customs codes for cross-border e-commerce supervision (9610, 9710, 9810, etc.) and obtain the electronic data for the customs export declaration form. This is the core documentation for tax exemption without an invoice—without customs declaration data, tax authorities cannot verify the authenticity of the export, and the tax exemption cannot be granted.

Common Misconceptions: Many sellers believe that ”once I register a company in the Comprehensive Pilot Zone, I automatically qualify for the tax exemption.” In reality, all three conditions must be met simultaneously, and sellers must actively opt in to the tax exemption policy when filing their tax returns. If they do not actively file for the exemption, the tax authorities will treat the transaction as ”deemed domestic sales” and require them to pay the back VAT.

From registration in the Comprehensive Pilot Zone to electronic customs declarations, every step requires precise execution. Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the U.S., Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and other locations, as well as annual company audits, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI filing, FDI filing, and other corporate services, as well as Hong Kong residency application, renewal, and permanent residency services; Singapore EP application services; and cross-border e-commerce support and agency 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).

III. Differences in Tax Exemptions and Tax Refunds Under Different Regulatory Codes

Cross-border e-commerce involves a variety of customs classification codes, with different codes corresponding to different tax policies; sellers need to choose the appropriate declaration method based on their business model.

9610 (Cross-Border B2C E-Commerce): This applies to B2C small-package direct mail exports and represents the core application scenario for the tax-exemption policy for goods purchased without invoices. Under the 9610 model, goods purchased without invoices are eligible for tax exemption, while goods purchased with invoices are eligible for tax exemption and refund. The 9610 model requires enterprises to complete cross-border e-commerce qualification filing and submit declarations through the ”Single Window” for international trade.

9710 (Cross-border E-commerce B2B Direct Export): Applicable to large-scale B2B exports. Under the 9710 mode, enterprises may apply for tax refunds through the general trade procedure (requiring input invoices) or, when eligible, avail themselves of the tax-exemption without invoices. However, there is some controversy regarding the practical implementation of the tax-exemption without invoices under the 9710 mode, as some local tax bureaus require enterprises to provide additional supporting documentation.

9810 (Cross-border E-commerce Export Overseas Warehouses): Applicable to exports shipped via overseas warehouses. Under the 9810 model, sales are not recognized when goods are exported to an overseas warehouse; revenue must be recognized upon the final sale. The “tax-exempt without an invoice” rule also applies, but under the overseas warehouse model, compliance with the destination country’s VAT regulations must also be ensured.

1210 (Bonded Stockpiling for Export): Applicable to exports following stockpiling in bonded warehouses. The tax-exemption policy for goods without invoices under the 1210 model also applies, and the tax-exemption policy for returned goods (extended through December 31, 2027) provides additional risk protection for the bonded stockpiling model.

Key Practical Tips: If a company engages in both invoiced and non-invoiced purchases, it must account for them separately in its books. The invoiced portion is processed through the tax refund system, while the non-invoiced portion is processed through the tax-exemption system. Mixing the two may result in delays in tax refund approvals or failure to qualify for tax exemptions.

IV. Pathways to Compliance for Procurement Without Invoices and Accounting Treatment

Tax-exempt transactions without invoices resolve tax issues on the ”export side,” but compliance on the ”purchase side” is equally important. Although long-term purchases without invoices do not result in a VAT liability under the tax-exemption policies of the comprehensive pilot zone, they still pose risks in terms of corporate income tax.

Option 1: Seek to obtain invoices from upstream suppliers. For suppliers with whom a company has a stable business relationship, the company should encourage them to obtain tax registration and issue invoices. Even if a supplier is a small-scale taxpayer, a 3% special VAT invoice is sufficient to complete the tax refund process. Qicaiying can assist sellers in connecting with compliant suppliers, thereby resolving invoice issues at the source.

Option 2: Standardization of Procurement Contracts. Purchases made without invoices must be supported by a formal purchase contract that clearly specifies details such as the item description, quantity, unit price, delivery terms, and acceptance criteria. The contract serves as the key documentation proving the authenticity of the purchase; during tax audits, purchases made without a contract or invoice are highly likely to be deemed ”fictitious costs.”

Option 3: Traceable cash flow. Payments for purchases should be made through the company's business account; avoid using personal accounts for payments. Bank statements, together with purchase contracts and goods receipt slips, form a complete chain of evidence and are key to proving the authenticity of business transactions.

Path 4: Accounting Standards. Key points for accounting treatment of tax-exempt exports without invoices include: When recognizing export sales revenue, debit ”Accounts Receivable/Bank Deposits” and credit ”Operating Revenue”; at the same time, because the tax-exemption policy applies, the corresponding input tax cannot be deducted and should be included in the cost of goods sold. When filing the monthly return, report the tax-exempt export revenue without an invoice in the ”Tax-Exempt Sales” section of the VAT return form and retain the electronic data from the customs export declaration form for future reference.

Option 5: Annual Tax Settlement. To deduct the costs of purchases made without receipts from corporate income tax, ”reasonable supporting documents” are required. Although Announcement No. 28 of 2018 issued by the State Taxation Administration specifies that ”small-amount, sporadic business transactions” (defined as transactions of 500 yuan or less per transaction) may use payment receipts and internal documentation as supporting evidence for tax-deductible expenses, invoices are still required for large-value purchases made without invoices. It is recommended that enterprises obtain invoices whenever possible for purchases exceeding 5,000 yuan per transaction and retain payment receipts for small-amount purchases under 500 yuan.

From the application of the tax-free policy for invoice-free purchases to compliance reforms on the procurement side, tax and financial compliance for cross-border e-commerce is a systematic endeavor. 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 services such as annual company audits, bookkeeping and tax filing, tax compliance, business registration changes, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong residency application, renewal, and permanent residency services; Singapore EP application services; and one-stop support for cross-border e-commerce, including on-the-job 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).

The tax-exemption policy for transactions without invoices has opened a door to compliance for cross-border e-commerce sellers, but entering through this door requires meeting three conditions: selecting the correct regulatory code, maintaining proper accounting records, and ensuring procurement compliance. Against the backdrop of increasingly stringent big-data oversight under the Golden Tax Phase IV initiative, ”no invoice does not mean no risk”—only by combining tax exemptions on the export side with procurement compliance can cross-border e-commerce businesses truly achieve sustainable operations.