A leading cross-border e-commerce company in Shenzhen was ordered to pay over 80 million yuan in back taxes and late payment penalties for ”underreporting export revenue and abusing the fixed-rate taxation system.” This is not an isolated case—in the first half of 2026, the State Taxation Administration launched a special audit campaign targeting the cross-border e-commerce industry, recovering more than 4 billion yuan in back taxes in the first five months alone. An Amazon seller in Dongguan received $1.8 million in foreign exchange through a personal account without filing customs declarations or tax returns, ultimately facing a total of 6 million yuan in back taxes, fines, and late payment penalties. As of the first half of 2026, nearly 70 A-share listed companies had issued announcements regarding back taxes, with cumulative back taxes, late payment penalties, and fines exceeding 5 billion yuan.

Behind these figures lies a fundamental shift in the tax regulation model for cross-border e-commerce: the scope for fixed-rate taxation has been significantly narrowed, and audit-based taxation has become the sole option. Starting in 2026, cross-border e-commerce enterprises will, in principle, be subject to audit-based taxation—every item of revenue, cost, and expense must be supported by legitimate and valid documentation, and expenses without supporting documentation may not be deducted for tax purposes. However, audit-based taxation does not necessarily mean ”paying more taxes.” A key favorable policy is being implemented simultaneously: the legal recognition of overseas documentation—including overseas invoices, platform fee statements, and bills from overseas logistics providers—which can serve as valid documentation for tax-deductible expenses when they meet the required criteria. This means that the long-standing issue of ”no invoices from overseas”—which has plagued cross-border e-commerce businesses—finally has a clear policy solution. If you are the owner or CFO of a cross-border e-commerce company with annual revenue ranging from 10 million to 100 million yuan and are concerned about establishing an accounting system compliant with the audited tax assessment system, you can contact Qicaiying Group to obtain financial and tax compliance guidance and support for the audited tax assessment system. Qicaiying Group operates its own accounting firm and a licensed secretarial company. With a professional team of approximately 400 people, we have served over 18,000 corporate clients and can provide end-to-end services including guidance on audit-based taxation for cross-border e-commerce, compliance for overseas documentation, independent bookkeeping, and tax filing.Hotline: 18676749275. Add us on WeChat: Qicaiyingjituan.

I. Replacement of Fixed-Rate Taxation with Audit-Based Taxation: Policy Rationale and Implementation Guidelines

Policy Background: Announcement No. 36 of 2019 issued by the State Taxation Administration previously stipulated that enterprises registered in comprehensive pilot zones, conducting 9610 retail exports, and genuinely unable to obtain purchase invoices could be subject to assessed taxation based on a 4% profit margin. However, in 2026, two factors combined to completely eliminate the scope for this practice: First, the “Golden Tax Phase IV” initiative fully integrated industrial and commercial, tax, banking, customs, social security, and e-commerce platforms, enabling real-time data sharing across more than 40 departments and 138 categories of data; Second, Announcement No. 15 of 2025 issued by the State Taxation Administration requires platforms such as Amazon, TikTok Shop, and Temu to report sellers’ sales revenue, order volume, and refund amounts to tax authorities on a quarterly basis.

Implementation Guidelines: Starting in 2026, cross-border e-commerce enterprises will, in principle, be subject to tax assessment based on audited financial statements. For eligible existing business conducted in 2025 and prior years, final tax filings may be completed in accordance with established policy guidelines (using a 2% taxable income rate for January–September 2025 and a 4% rate for October–December 2025). Thereafter, every item of revenue, cost, and expense reported by enterprises must be supported by legally valid documentation. The 9810 overseas warehouse model has never been explicitly authorized for tax assessment under national policy; starting in 2026, all overseas warehouse sellers will be subject to tax assessment based on audited accounts.

Core changes: The platform’s reporting criteria are based on the full transaction amount actually paid by the buyer. Fees deducted by the platform—such as commissions and advertising fees—are considered operating costs; reported income should not be reduced due to these deductions. Discrepancies between reported income and the data submitted by the platform serve as an important basis for tax authorities to identify risks. To put it simply: If you sell 1 million in goods on the platform, the platform reports 1 million, but you report 600,000—the system will automatically flag that 400,000 discrepancy.

II. Legalization of Overseas Invoices: A Solution to the ”Invoice-less Dilemma” in Cross-Border E-Commerce

The most groundbreaking provision in the 2026 audit-based taxation guidelines is the legal recognition of foreign documents.

Overseas documents that qualify as pre-tax deduction vouchers include: Foreign invoices, platform fee breakdowns (advertising fees, commissions, warehousing fees, refund processing fees, etc.), invoices from international logistics providers (DHL, FedEx, 4PX, etc.), breakdown of overseas warehousing fees, invoices for overseas certification fees (e.g., NRCS certification, SABS certification, etc.), and invoices for overseas legal, consulting, and auditing fees.

Document Compliance Requirements: Documents must be originals or notarized copies; they must include basic information such as the payee’s name, amount, service details, and date; they must correspond to the actual business transactions (logistics invoices must match the customs declaration or order data); Foreign-language documents must be accompanied by a Chinese translation (stamped by a translation company or issued by an institution with translation certification).

The significance of this policy: In the past, the biggest tax challenge for cross-border e-commerce was the inability to obtain invoices for overseas expenses—platform advertising fees were documented only by electronic statements, overseas logistics were documented only by waybills, and overseas warehouses were documented only by system deduction records. which were not an issue during the fixed-rate taxation era (since no deductions were allowed under the 4% assessment method), but became a fatal flaw during the audited taxation era—without supporting documents, expenses could not be deducted for tax purposes, leading to inflated profits and, consequently, a heavier tax burden. The legalization of overseas supporting documents has resolved this dilemma of ”having costs but no supporting documentation.”

Hands-on advice: From now on, systematically retain and file all receipts for overseas expenses. Export monthly breakdowns of platform fees and print them for filing; reconcile logistics provider invoices monthly and keep copies; and regularly export and save detailed breakdowns of overseas warehouse fees. These receipts will serve as your ”right to claim input tax credits” during future tax audits and assessments.

III. Integration of the Three and Four Flows: Sales Flow, Logistics Flow, Customs Clearance Flow, and Cash Flow

Under the audit-based tax collection system, the core compliance framework is the ”integration of the four flows”—data across these four dimensions must be cross-verified and consistent in definition.

Sales Flow: Order data, refund data, and settlement reports from the platform’s backend. This is the data the platform submits to the tax authorities on a quarterly basis. Your reported revenue must match the platform’s reporting criteria; discrepancies exceeding the threshold will trigger a system alert.

Logistics Flow: The actual flow of goods. Whether shipped from China to overseas warehouses or from overseas warehouses to consumers, logistics documents for each stage (waybill numbers, delivery receipts, and return shipping records) must be retained. Logistics data is used to verify the authenticity of sales data—where there are sales, there is logistics; where there is logistics, there are sales.

Customs Clearance Process: Export customs declaration data. The customs declaration serves as the legal basis for tax refunds and the recognition of export revenue. The declared value must match the platform’s sales data and payment receipt data. “Proxy export” (exporting your own goods using someone else’s customs declaration) is completely impossible under the Golden Tax Phase IV system—customs authorities have your export data, and the tax bureau has your platform revenue data. When these two sets of data are cross-referenced, any sales recorded without a corresponding customs declaration will be immediately exposed.

Cash Flow: Foreign Exchange Repayment Channels. The State Administration of Foreign Exchange (SAFE) has a thorough understanding of the capital repatriation pathways for overseas receipt accounts. The ratio of repatriations to corporate versus personal accounts (where personal account repatriations exceed 30% is flagged as high-risk) and the consistency between export value and repatriated funds (where a discrepancy exceeding 20% triggers an alert) are all subject to monitoring.

Inspection Criteria for the Integration of the Four Streams: For every order, corresponding records can be found across four dimensions—sales flow (platform orders), logistics flow (waybills), customs clearance flow (customs declarations), and cash flow (payment records)—and the amounts reported are generally consistent. Businesses that cannot align these four flows are considered risk points under the audit-based taxation system.

IV. Separate Accounting: Each store is a separate taxpaying entity.

Tax regulations for 2026 have been clarified: Each store is considered a separate taxable entity and must file its own tax return.

Why can't we consolidate the accounting records? The old tactic of having ”all ten stores file zero tax returns while keeping all profits in Hong Kong” has become completely ineffective in the era of platform data reporting. When platform data is pushed to the mainland, zero tax returns directly contradict the platform data, triggering an automatic system alert. The tax authorities compare ”platform-reported data” with ”company-filed data”; if the reported revenue is significantly lower than the platform data, a “Tax Risk Alert Letter” is sent directly to the company’s desk.

Requirements for maintaining separate accounting records: Each store or company must have a separate bank account, separate revenue recognition, separate cost allocation, separate expense allocation, and separate tax filings. Transactions between affiliated companies must be priced in accordance with the arm’s-length principle, and profits must not be artificially shifted through related-party transactions.

Key Points for Cost Allocation: Purchasing costs must be supported by special VAT invoices (to qualify for tax credits and refunds); overseas expenses must be supported by compliant documentation (overseas invoices, statements, or itemized receipts); labor costs must be supported by social security contribution records and payroll documentation; and warehousing and logistics costs must be supported by contracts and invoices.

Lessons from the 80 Million Case in Shenzhen: The company has long been using the 0110 general trade export customs declaration procedure; the goods are actually shipped to overseas warehouses in the United States for sale, and the proceeds are intercepted through a Hong Kong company account before being split up and transferred to multiple private accounts within China. A comparison conducted by the Golden Tax Phase IV system revealed: a severe discrepancy between the declared export value and the amount of proceeds received in the corporate account; a clear mismatch between the number of employees reported for social insurance contributions and the actual size of the warehouse team; and a large number of suspicious patterns in bank transaction records, characterized by ”overseas inflows → split transfers.” Ultimately, the company was required to pay back taxes and late payment penalties totaling more than 80 million yuan and faces fines ranging from 0.5 to 3 times that amount.

V. Qicaiying Professional Service Package: Guidance on Tax Assessment Based on Audited Accounts and Establishment of an Accounting System

In response to the full implementation of audit-based taxation for cross-border e-commerce, Qicaiying Group offers enterprises end-to-end service solutions:

(1) Feasibility Assessment of Tax Assessment Based on Audits. Assess whether the company’s current accounting system meets the requirements for audit-based taxation (separate accounting, complete documentation, and alignment of the four flows), identify historical risk areas, and develop a remediation plan and timeline.

(2) Compliance with regulations regarding offshore instruments. Guide companies to systematically retain, file, and ensure compliance with all overseas expense documentation (including platform fee statements, logistics provider invoices, overseas warehouse fees, and overseas certified invoices), to ensure they qualify as tax-deductible documents.

(3) Maintaining Separate Accounting Records and Filing Tax Returns. Assist each store’s company in establishing an independent accounting system, design rules for cost aggregation and expense allocation, and complete VAT, corporate income tax, and export tax rebate filings on a timely basis.

(4) Compliance Review of the Four Flows. Periodically cross-check a company’s sales, logistics, customs clearance, and cash flow processes to identify inconsistencies and implement corrective measures, thereby reducing the risk of system alerts.

(5) Resolution of historical legacy issues. We provide orderly resolution and compliance solutions for historical issues such as the settlement of tax assessments for existing business operations, the standardization of payments from private accounts, the rectification of export transactions involving third-party payments, and the cleanup of Hong Kong shell companies, thereby minimizing the risk of back taxes and penalties.

As a board member of the Shenzhen Cross-Border E-Commerce Association, Qicaiying Group operates its own accounting firm and a licensed secretarial company. With a professional team of approximately 400 people, the group has served more than 18,000 corporate clients to date and offers end-to-end services, including guidance on cross-border e-commerce audit-based taxation, compliance with overseas documentation requirements, independent bookkeeping, and tax filing.Hotline: 18676749275. Add us on WeChat: Qicaiyingjituan.

VI. Conclusion: Audit-Based Taxation Is Not a Punishment, but a Return to the Essence

The essence of audit-based taxation is not to ”make cross-border e-commerce businesses pay more taxes,” but to ”ensure that taxes owed are verifiable.” The low tax burden during the era of assessed taxation was not a policy benefit, but rather a ”benefit of information asymmetry” arising from regulatory blind spots. Once the Golden Tax Phase IV system and platform reporting eliminate this information asymmetry, this benefit will inevitably disappear.

However, the audit-based taxation system also brings an often-overlooked benefit: the legalization of overseas receipts. Now that the past dilemma of ”being unable to obtain invoices for overseas expenses” has been resolved, the actual tax burden for compliant sellers may not be much higher than it was during the era of assessed taxation—as long as documentation is complete, the “four flows” align, and eligible credits and deductions are claimed, the actual tax burden under the audited accounting system can be kept at a reasonable level.

The difference is this: During the fixed-rate taxation era, the tax burden was roughly the same for compliant and non-compliant sellers (since everyone was taxed at 41% TP and 3% TP); Under the audited assessment system, compliant sellers may actually face a lower tax burden than non-compliant sellers (because compliant sellers can claim tax credits and deductions, while non-compliant sellers, lacking supporting documentation, must inflate their profits and end up paying more in taxes). Compliance is shifting from being a ”cost” to a ”competitive advantage.”

If you would like the system to assess your company’s readiness for audited tax assessment and develop a compliance plan, please contact Qicaiying Group to receive one-on-one financial and tax compliance consulting services.For inquiries, call 18676749275 or add us on WeChat: Qicaiyingjituan.