Recently, many cross-border e-commerce sellers have received a copy of the "Cross-border e-commerce export enterprise research outline" from the tax department. This research outline is a positive signal that the tax department has taken the initiative to extend the olive branch and seek to understand the industry's pain points, and it faces the cross-border industry's core dilemma in the long run. If you have received this research outline, you can take this opportunity to take immediate action, participate in the research, actively participate in the industry policy formation process, and grasp this critical window.

Currently, cross-border e-commerce exporters are facing multiple problems such as long tax refund cycle, high management cost, and difficult policy implementation under the major regulatory modes such as 0110, 9810, and 9610, etc. The introduction of the relevant tax-related announcements in 2025 further aggravates the compliance confusion for enterprises with multi-store operations and offshore structures.

Policy challenges such as tax rebates under different modes of exports

Different export supervision modes present differentiated pain points in tax rebate and policy application due to different adaptation scenarios, among which 0110, 9810 and 9610 are commonly used modes by enterprises, and the problems are particularly prominent.

0110: Long Tax Refund Cycle Drags Down Capital Flow

0110 (general trade) has become the preferred choice of most enterprises due to mature customs clearance and fast timeliness, but in recent years, the tax rebate cycle has been extended in some areas, which has significantly affected the capital turnover of enterprises.

This mode is adapted toIntegrated national customs clearanceThe tax return efficiency is especially suitable for sellers who stock overseas warehouses, but the decline in the efficiency of tax return directly increases the cost of capital occupation of enterprises, which has become a major obstacle in the current use of it.

9810: Difficulty in landing with many practical barriers

Although 9810 (cross-border e-commerce export overseas warehouse) is suitable for overseas warehouse stocking scenarios, the high cost of multi-store management, complex financial accounting, and vague definition of tax rebate have led to few enterprises actually adopting it.

Under multi-store operation, separate customs declaration will significantly increase the workload of tax personnel and management costs; the financial level needs to integrate domestic and overseas income, cost and inventory, and "one export, multiple sales" makes it difficult to match the customs declaration with the sales flow, which makes it more difficult to audit. In addition, the eligibility for tax refund for overseas goods removal, abandonment, loss and refund only scenarios is not clear, and the problem of deduction of platform commissions exceeding the limit is not solved, and the superimposed tax refund is often hindered by tax and foreign exchange collection issues, so enterprises prefer 0110 mode.

9610: Uninvoiced purchases and compliance costs are both high

9610 (cross-border trade e-commerce) mainly solves the problem of customs clearance for direct mail parcels, but non-invoiced purchases lead to inflated income tax, shortage of qualified service providers, difficulties in data sharing, etc., and it is extremely difficult to export in a compliant manner.

Fragmentation of parcel purchases leads toDifficulty in obtaining invoicesIn addition, the policy of tax exemption and authorized collection without invoices has not been implemented enough, and the income tax is on the high side if the enterprises declare in compliance, so some enterprises have no choice but to choose to buy a bill for export. At the same time, the limited number of qualified service providers and the lack of national integrated customs clearance, non-port enterprises need to transit transportation, increasing logistics and time costs; customs and tax data sharing mechanism is not perfect, the difficulty of transferring the data of customs clearance to the local tax, further restricting the compliance process.

1039, 9710: limited adaptation scenarios difficult to popularize

1039 and 9710 are unable to meet the policy needs of most cross-border e-commerce companies due to their narrow applicability groups.

1039 (Marketplace Purchasing) is only applicable to sellers purchasing from fixed collection areas, with limited coverage; 9710 (Cross-border E-commerce B2B Direct Export) is mainly adapted to sellers on B2B platforms such as Ali's International Station, and does not match the business scenarios of sellers on B2C platforms such as Amazon.

Impact of new tax regulations and issues for the industry in 2025

The introduction of Announcement No. 15 of 2025 on Matters Relating to the Reporting of Tax-Related Information by Internet Platform Enterprises and Announcement No. 17 on Matters Relating to the Optimization of Enterprise Income Tax Advance Payment Tax Returns has caused multi-store operations and enterprises adopting an offshore structure to face problems such as ambiguity in defining the main body of tax payment and duplication of income declarations, and the industry has experienced a wait-and-see stagnation.

Multi-store operation is a common mode of the industry, enterprises usually through the actual operating body in the territory to undertake procurement, sales functions, offshore companies (such as Hong Kong companies) to realize the business of the closed loop, the store company is only the registered subject is not actually operating.

After the announcement required the platform to report tax-related information, the store data was inconsistent with the data of the actual business entity, and some regions required the store company to correct the declaration, which led to the risk of duplicate taxation for enterprises that had already paid taxes in the actual business entity. At the same time, the lack of procurement and logistics invoices for store companies makes it impossible to complete the declaration, and the compliance of offshore structure is not clear, so some enterprises suspend the preparation of goods or turn to register stores overseas, which affects the normal development of business.

In addition, there are differences in the calibre of local implementation of revenue recognition and the definition of taxable entities:

• Recognition of pre-tax deductions for expenses such as commissions and advertising fees for offshore platforms varies, with some regions requiring withholding and payment of VAT;
• The criteria for payment of VAT when the amount declared does not correspond to the amount received are unclear;
• Different jurisdictions have different requirements for back taxes for offshore structured enterprises, and some jurisdictions do not accept business model explanations and require mandatory corrective filings.

Core recommendations for solving policy challenges

Solving the cross-border e-commerce policy pain points requires multi-sectoral collaboration to optimize the regulatory model, clarify the path to compliance, adjust the tax policy to match the industry, and promote the industry's smooth compliance.

 Optimization of the core regulatory model landing mechanism

For the two key modes of 9810 and 9610, it is recommended that the tax, customs and foreign exchange departments work together to improve their policies:

• Simplify the 9810 multi-store customs declaration process, clarify the rules for tax refunds for overseas goods disposal and refund-only scenarios, and relax the income tax deduction limit for platform commissions and other expenses;
• It has accelerated the landing of 9610 national integrated customs clearance, expanded the coverage of the no-ticket tax exemption and authorized levy policy, cultivated more qualified service providers, and opened up cross-departmental data-sharing channels.

Clarifying the compliance path for multi-store and offshore structures

Recognizing the industry's widespread adoption of "Safeway model"Proven architectures such as this one allow companies to pass store companiesFiling and strengthening offshore company regulationThe way to achieve compliance, after the filing of the store company does not need to recognize revenue separately, by the actual operating entity unified accounting;

If the main body of the store is required to declare its income, the centralized purchasing body can be allowed to export to an offshore ODI company, and then the store can purchase from the offshore company and account for it independently, so as to simplify the tax refund process.

Implementation of transitional policies to stabilize industry expectations

Specialized filing guidance is provided to companies that have complied with the July-September 2025 tax, and non-compliant companies are given policy counseling rather than direct penalties to avoid significant industry volatility;

In the case of past purchase orders for export and non-taxable goods, VAT exemption may be granted to guide enterprises to shift to compliant customs declarations and to increase penalties for subsequent violations.

Adjustment of tax policies to accommodate new businesses

Optimize the enterprise income tax deduction rules for the characteristics of the cross-border e-commerce industry and increase the deduction limit for platform commissions, advertising fees and other expenses.

Clarify the eligibility for pre-tax deduction of offshore procurement vouchers, and recognize vouchers such as pro forma invoices issued by Hong Kong companies in the case of restoration of declared income by the main body of the store to avoid double taxation.

Accelerating the process of policy clarification and implementation

Shorten the policy formulation cycle, issue clear compliance guidelines for multi-store operations, offshore structures and other scenarios as soon as possible, and unify the caliber of tax enforcement in various regions to eliminate compliance confusion and boost industry business confidence.

The export method conundrum and the impact of new regulations can be passedOptimize the model and clarify the pathCracking, suggesting that companies anchor their compliance paths and make good use of transition policies.

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