In 2026, a true ”hard switch” took place in the field of cross-border e-commerce taxation and finance:The fixed-rate tax collection method has been fully phased out, and the audited tax collection method has been fully implemented.In the past, some cross-border e-commerce companies took advantage of the ”fixed-rate taxation” policies in tax havens to “bundle” their income tax payments at a fixed percentage of sales revenue without maintaining complete accounting records; this practice has now been explicitly abolished by policy. This has been replaced by an audited assessment system in which every revenue transaction must be traceable in the books and every cost must be supported by documentation.

Underpinning this transition is the "Data Sky Net" established as part of the Golden Tax Phase IV initiative: data integration across four sectors—taxation, customs, banking, and online platforms—covering sales, logistics, customs clearance, and capital flows.four streams in oneCross-verification. Some companies have already paid a heavy price for this—in an audit case publicly disclosed within the cross-border e-commerce industry, the company involved concealed platform sales revenue and funneled funds back through personal accounts, ultimately resulting in the collection of back taxes, late payment penalties, and fines totaling approximately 95 million yuan. This is not a story where one can simply say, ”We’ll be more careful next time”; rather, it serves as a wake-up call for the entire industry.

For cross-border sellers, the question is no longer ”whether to comply,” but rather ”how to ensure compliance within the framework of audit-based taxation.” This article thoroughly explains the logic behind the transition, the “four-stream integration” standard, and the implementation path. If you wish to assess your company’s risk exposure under the audit-based taxation system, please contact Qicaiying Group to obtain a specialized compliance assessment. Qicaiying Group operates its own accounting firm and employs a professional team of approximately 400 people. It has served more than 18,000 corporate clients, providing one-stop services for tax compliance, financial statement reconstruction, export tax rebates, and cross-border tax matters.Hotline: 18676749275; Official WeChat: Qicaiyingjituan.

I. Why Now: The Three Logical Reasons for Phasing Out the Fixed-Rate Taxation System

Reason 1: Policy loopholes are being abused, so regulatory measures will inevitably be tightened. The assessed tax collection method was originally designed as a simplified tax collection approach for small and micro enterprises with inadequate accounting records and documentation. However, in recent years, some cross-border sellers have treated it as a ”tax planning tool”: they transfer profits to entities in tax havens and pay taxes based on an extremely low taxable income rate, resulting in an actual tax burden far below the statutory level. Such widespread abuse was bound to prompt policy tightening.

Reason 2: Platform data reporting eliminates the excuse of ”no records to check.” Following the implementation of the 2026 Tax Information Reporting System for Online Platforms (State Council Order No. 810 and Announcement No. 15 of 2025 by the State Taxation Administration), tax authorities will receive quarterly data on the identities and income of platform sellers. Once sales data is in the hands of the tax authorities, ”incomplete accounting records and supporting documents” will no longer serve as a justification for assessed taxation but will instead serve as a lead for tax audits. With this change in the data foundation, a shift in the tax collection method is an inevitable outcome.

Reason 3: Cross-border e-commerce has been explicitly brought under regulatory oversight. From tax-free purchases without receipts in comprehensive pilot zones and streamlined export tax rebates to the adoption of audited tax assessment for corporate income tax, the regulatory approach toward cross-border e-commerce has been consistent: the goal is not to stifle the industry, but to bring it into line with the standardized framework applicable to general trade. The phasing out of fixed-rate taxation is the final piece of the puzzle on this roadmap.

With these three lines of reasoning combined, the conclusion is clear: this is not a passing trend, but an irreversible institutional shift. Any ”wait-and-see” strategy is essentially gambling with the very survival of the company.

II. Integration of the Four Flows: The Benchmark for Compliance in the Era of Taxation Based on Account Records

The core of tax assessment based on accounting records lies in whether the records can withstand cross-verification of the four flows. The so-calledfour streams in one, refers to the sales process, logistics process, customs clearance process, and payment process for a single transaction being mutually corroborative and consistent in terms of data:

Sales Flow: Order data and sales revenue from platform stores. Under the platform reporting system, this data is held by the tax authorities. The compliance requirement is: a company’s reported revenue = platform order revenue (minus standard adjustments such as returns and platform fees).

logistics flow: Domestic shipping documents, international waybills, and overseas warehouse receipt records. Logistics data can reconstruct the actual flow and quantity of goods, serving as physical evidence to verify sales volume. While sales can be concealed, logistics cannot—this is a common avenue for auditors to uncover irregularities.

Customs Clearance Process: Export Customs Declaration Forms (declaration modes corresponding to customs supervision codes such as 9610, 9710, 9810, etc.). The consistency between the declared value on the customs declaration and the sales and payment amounts on the platform is the most critical comparison in cross-border business. Fictitious export declarations, undervaluation, and concealment of goods are impossible to hide under the data cross-checking mechanisms of the Golden Tax Phase IV system.

financial flows: Bank deposit records, third-party payment settlement records, and foreign exchange settlement records. Whether revenue is deposited into a corporate account or a personal account is the dividing line between compliance and non-compliance. One of the fatal flaws in the 95 million yuan case was precisely that the funds circulated outside the formal financial system through personal accounts.

The "Four-Stream Integration" evaluation criteria can be summarized in one sentence:Take any given transaction: the data from the four streams aligns seamlessly, the amounts are reconciled, and the timestamps correspond.If this is achieved, audit-based taxation is simply an extension of routine reporting; if not, every discrepancy becomes a starting point for an audit.

III. A Review of the 95 Million Case: How Did the Risks Accumulate Step by Step?

A review of high-profile cases exposed within the industry reveals a striking consistency in the risk pathways, making it worthwhile for every seller to conduct a self-assessment:

Step 1: Connect to extracorporeal circulation.Platform payments are collected via third-party payment services or personal bank cards and do not go into corporate bank accounts, resulting in companies reporting revenue that is significantly lower than actual sales. When the data reported by the platform is compared with the reported data, the discrepancy becomes immediately apparent.

Step 2: No receipts for expenses, resulting in inaccurate accounting records.When purchasing goods, companies may be unable to obtain invoices from manufacturers, or they may voluntarily forego invoices to drive down prices, leaving no documentation to support their costs. Under the audited assessment system, costs without invoices cannot be deducted for tax purposes, which distorts reported profits and causes the tax base for back taxes to grow exponentially.

Step 3: Disconnect between customs clearance and sales.Some goods are exported under a purchase invoice or with undervalued declarations, causing discrepancies between customs clearance records, sales records, and cash flow records; cross-checking customs data with tax data directly identifies these anomalies.

Step 4: An alert is triggered when funds flow back into a personal account.Large-amount, high-frequency deposits into personal accounts triggered joint anti-money laundering and tax alerts from the bank, and the flow of funds became the final piece of evidence closing the loop on the entire case.

Step 5: A multi-year retrospective—from quantitative change to qualitative change.After auditing and tracing years of operational data, the combined total of taxes, late payment penalties, and fines turned what was once ”saved in taxes” into ”a cost several times higher.” Behind the figure of 95 million yuan lies the compounding accumulation of risks over many years.

The most important lesson to take away from this case is that, at the time, every step was considered ”industry practice,” but integrating data turned all those practices into a chain of evidence. Risks accumulate gradually, but they are exposed all at once.

IV. Eight-Step Compliance Action Checklist: Implementation Path for Account-Based Taxation

To shift from a fixed-budget mindset to a cash-based mindset, companies can follow these eight steps:

Step 1: Record all revenue.All sales revenue from platform stores (including multiple platforms and multiple entities) is recognized and recorded in full; a reconciliation mechanism is established with the data reported by the platforms, and discrepancies are reconciled on a monthly basis.

Step 2: Centralized Fund Management.All platform payments must be routed to corporate bank accounts or compliant third-party payment channels; the use of personal bank cards for business-related payments must be completely discontinued, and historical transaction records in personal accounts must be reviewed and brought into compliance.

Step 3: Convert the procurement process to a bill-based system.Renegotiate invoice collection arrangements with suppliers and gradually phase out purchases made without invoices; for cases where invoices truly cannot be obtained, assess the possibility of applying the tax-exemption policy for purchases without invoices in the Comprehensive Pilot Zone to provide a policy solution for ”invoice-less” transactions.

Step 4: Finalize the customs clearance method.Select the appropriate regulatory models based on the nature of the business—such as 9610 (retail direct mail exports), 9710 (cross-border e-commerce B2B direct exports), and 9810 (cross-border e-commerce exports to overseas warehouses)—to ensure that all required declarations are filed and that all information is reported accurately.

Step 5: Establish accounting records and systems.Establish a comprehensive accounting system in accordance with accounting standards; clarify equity and business boundaries for entities operating multiple stores to avoid commingling of operations; and align the timing of revenue recognition with the new Value-Added Tax Law and corporate income tax regulations.

Step 6: Proper Application of Tax Incentives.Policies such as tax incentives for small, low-profit enterprises, additional deductions for R&D expenses, export tax rebates (or exemptions), and tax exemptions for transactions without invoices should be fully utilized—provided they are implemented in compliance with regulations. Tax planning in the era of audit scrutiny involves the precise application of policy benefits, not the concealment of the tax base.

Step 7: Resolving historical issues.Conduct a special assessment of revenue shortfalls and bill shortfalls from prior years, calculate risk exposure, evaluate the cost difference between voluntarily correcting tax returns and undergoing a tax audit, and take advantage of the policy provisions regarding ”no penalty for a first-time violation” and ”leniency for voluntary payment of back taxes.”

Step 8: Establish a long-term mechanism.Establish regular procedures for monthly reconciliation of the four cash flows, quarterly compliance self-inspections, and annual tax settlement reviews, thereby transforming compliance from a one-time task into an integral part of business operations.

V. Qicaiying Professional Service Plan: From Risk Assessment to Long-Term Compliance

Qicaiying Group provides cross-border e-commerce companies with full-cycle services for audit-based taxation, covering ”diagnosis—correction—long-term operations”:

(1) Risk Assessment Based on the Integration of the Four Flows: The platform aggregates data from four categories—sales, logistics, customs clearance, and banking—to perform cross-checks, generating quantitative risk exposure reports and prioritizing corrective actions.

(2) Restructuring the Accounting System: Accounting setup and system implementation services for enterprises with multiple stores and legal entities, ensuring full-process compliance in revenue recognition, cost allocation, and invoice management, and leveraging the delivery capabilities of our in-house accounting firm.

(3) Special Campaign to Resolve Historical Issues: Compliance solutions for historical revenue shortfalls and bill shortfalls; operational guidance on voluntary corrections to tax returns; and efforts to secure lenient treatment within the policy framework.

(4) Export Tax Rebates and Cross-Border Special Programs: Agency services for export tax rebates (or exemptions), planning for 9610/9710/9810 declaration modes, guidance on applying for tax exemptions without invoices in comprehensive pilot zones, and reconciliation management of data submitted via the platform.

(5) Tax Planning and Cross-Border Structures: We coordinate the Group’s tax burden in compliance with regulations and, by leveraging offshore structuring and transfer pricing services in over 40 countries and regions—including Hong Kong and Singapore—we help sellers operating at scale establish a sustainable tax framework.

As a board member of the Shenzhen Cross-Border E-Commerce Association, Qicaiying Group has a professional team of approximately 400 people and a licensed secretarial company, and has served more than 18,000 corporate clients to date. The transition to audit-based taxation has been completed, and risks will not wait for those who hesitate.For inquiries, call 18676749275 or add us on WeChat: Qicaiyingjituan.

VI. Conclusion: Only by keeping accurate books can a business thrive in the long run

The phasing out of the fixed-rate tax collection method marks the end of the era when cross-border e-commerce businesses ”made money quietly”; the implementation of the “four-stream integration” principle, meanwhile, sets the operational standards for the new era—accurate accounting, genuine goods, clear financial records, and transparent taxation. In the short term, compliance entails costs and growing pains; but over the long term, it means a predictable tax burden, clean financial statements, a corporate structure suitable for financing and mergers and acquisitions, and the confidence to withstand any tax audit.

The 95 million yuan case serves as a warning about the risks, while the Eight-Step Checklist provides a roadmap. From risk assessment to establishing long-term mechanisms, there are professional methods to follow at every step. The key is to start as early as possible—the data is already in the tax system, and every day that the books remain unaccounted for is a period during which risk exposure continues to accumulate. If your company is currently experiencing the growing pains of transitioning to audit-based taxation, please contact Qicaiying Group to receive a one-on-one compliance assessment and implementation plan.Hotline: 18676749275; Official WeChat: Qicaiyingjituan.