In the cross-border e-commerce industry, "purchasing without tickets" is almost a common pain point for millions of sellers.Upstream small and medium-sized factories do not want to invoice, invoicing additional tax points, in order to control costs, many sellers can only helplessly choose to take goods without tickets.However, with the tightening of Golden Tax Phase IV regulation and the normalization of tax audits, theUnbilled purchases bring difficult cost accounting, tax early warning, audit and tax reimbursement and other risksThe "Sword of Damocles" has long been hanging over the heads of sellers.
Previously, the crude mode of relying on buy orders for export and private accounts for collection has long been unworkable, and compliance modes such as 1039 market procurement and 9610/9810 authorized collection have become the core options for sellers to crack the problem of procurement without tickets.
Get an in-depth teardown today!4 Compliance Options for Cross-Border E-Commerce Procurement without TicketsIn addition, with the real practice cases, from the application of the scene, the core advantages to the practical points one by one, to help different volumes, different modes of operation of the seller accurate matching, to achieve compliance and cost reduction both! Be sure to see the end, the end of the exclusive compliance consulting benefits to help you take the wrong road. Welcome to sweep the code to add our online customer service (micro letter: jxhqcy890 / cell phone: 16625410105), arrange the manager to answer questions, provide professional advice and full one-on-one service!

01.Why compliance with ticketless purchasing is urgent?
Before we talk about solutions, let's be clear about one core fact: purchasing without tickets is not a "money saver", but a "mine".
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Sellers choose to purchase without a ticket, there are only two main reasons: first, the upstream supply chain is dominated by small and medium-sized factories, the enterprise scale is small, the financial system is not sound, and it is unable to provide a compliant VAT invoice; second, although some of the suppliers are able to issue invoices, they will be charged an additional 6%-13% tax points, which is overlaid on the operating costs of cross-border e-commerce, and a lot of sellers choose not to have a ticket in order to have an immediate interest.
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But the cost of purchasing without a ticket is much higher than that tax point:
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[Real warning case]
Shenzhen, a small and medium-sized Amazon seller, mainly engaged in 3C accessories, annual sales of 8 million, the upstream suppliers are mostly small workshops in Dongguan, are unable to provide VAT invoices. The seller in order to control costs for a long time without invoices procurement, using the buy single export mode, 2025 was the tax department audit, because of the inability to provide the cost of invoices, was approved by the high profit, need to pay back the corporate income tax of 320,000 + 80,000 late fees, a total of 400,000, equivalent to half a year of net profit, but also be included in the tax focus on the list of regulators, the store was once frozen back to the money.
What's more tricky is that the upstream suppliers were unwilling to cooperate with the supplementary vouchers, resulting in compliance rectification taking 3 months, during which time they were unable to make normal customs declarations and shipments, and directly lost orders of 1.2 million.
Instead of procrastinating with a fluke, it is better to take the initiative to match the compliance mode and kill the tax risk at the source. The following four models, covering the whole scenario from small and medium sellers to medium and large sellers, from direct mail to overseas warehouses, and from domestic subjects to cross-border structures, are the optimal solutions for compliance of invoice-less purchasing that have been verified in the industry.
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02.Model I: 1039 Market Purchase Trade
1039 Market Purchase Trade ModelIt is an exclusive policy launched by the state to support small and medium-sized foreign trade enterprises, and is also the easiest to land and the lowest threshold of compliance mode for ticketless procurement sellers, especially suitable for small and medium-sized cross-border sellers with annual sales of less than 20 million.
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1. No invoices to report, exempt from VAT: In response to the pain point of purchasing without invoice, the 1039 model allows sellers to handle export customs clearance without VAT invoice and is exempted from export VAT, so there is no need to pay extra for the invoice issue;
2. Low thresholds and simplified processes: You can be stationed in the record, without complex import and export rights qualification, customs clearance, inspection, tax rebates, the whole process is simplified, small and medium-sized sellers are easy to operate;
3. cost-controllableThe company has been able to realize the sunshine of customs declaration and legal collection of foreign exchange without bearing the tax point of invoicing, and completely bid farewell to the gray area of bill of lading for export;
4. wide application: It is suitable for sellers of small commodities and miscellaneous pickups, covering mainstream platforms such as Amazon, Sizzle, Shopee, etc., and supports LCL export.
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1. Required to be recognized at customsMarket Purchase Trade ClusterComplete the filing (there are several pilot regions in China, sellers can choose the nearest one, such as Yiwu, Guangzhou Huadu, Wenzhou Lucheng, etc.);
2. The value of a single customs declaration does not exceed$150,000, which is suitable for small quantity and multi-batch shipment mode;
3. Customs declaration should be completed through the integrated market procurement trade management system, and the collection of foreign exchange should follow the formal foreign exchange channel, so as to realize the consistency of the three streams of "customs declaration, collection of foreign exchange and logistics".
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Dongguan, a small factory doing hardware accessories, the main cross-border Shopee platform, annual sales of 4 million, the upstream are small raw material suppliers (mostly family workshops), can not provide VAT invoices, previously has been relying on gray channels to buy single export.I am afraid to take large orders for fear that my foreign exchange account will be frozen and my store will be penalized.
In 2025, the seller registered as an individual in the Yiwu Market Purchasing Cluster, completed the 1039 mode filing, and all the hardware fittings purchased without invoices were declared for export through the 1039 mode without the need to provide input invoices, and were exempted from the export value-added tax (VAT).The consolidated tax burden is kept within 3% (only a small amount of authorized business income tax is paid).
After the rectification, the seller completely said goodbye to the compliance risk, not only dare to boldly undertake large orders, the first half of 2026 exports exceeded 2.5 million, the speed of capital return has also greatly increased (formal collection of foreign exchange without fear of being controlled), but also save the previous buy single export fee (calculated by the value of goods 0.5%, annual savings of 20,000 +).
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Annual sales of less than 20 millionThe small and medium-sized cross-border sellers with a high percentage of non-ticketed purchases and a focus on direct mail/small-volume shipments are especially suited toSellers whose supply chains are concentrated in Yiwu, Guangzhou, Wenzhou and other 1039 pilot regions, as well as sellers of small items and miscellaneous pickups.
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03.Model II: 9610/9810 authorized levy
9610 (cross-border e-commerce direct mail exports) and 9810 (cross-border e-commerce exports to overseas warehouses) are the exclusive customs supervision codes for cross-border e-commerce, and theApproved levyOn the other hand, it is a tax incentive for sellers of non-ticketed purchases, and the combination of the two has become a core compliance option for medium and large sellers with annual sales of more than 20 million dollars, especially adapted to the mode of Amazon FBA and independent station overseas warehouse.
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1. Approved costs without invoices, lower corporate income tax::In response to the inability to accurately account for costs for purchases made without invoices, the tax department presses theAuthorized profit marginLevy corporate income tax (the industry generally approved profit margin of 4%-10%), without invoices can be legally deducted, significantly reducing the tax burden;
2. Dedicated policies and standardized processes::9610/9810 is a cross-border e-commerce exclusive modelIn addition, customs and tax departments have supporting regulatory processes, and the whole chain of customs declaration, remittance, and tax refund (tax exemption/simplified tax under approved levy) is standardized, which is suitable for large-scale operation;
3. 9810 is suitable for overseas warehousing, 9610 is suitable for direct shipping::The two modes can be flexibly switched according to the shipping method. 9810 is exempted from export VAT and sunshine collection, which perfectly matches the overseas warehouse modes such as Amazon FBA; 9610 is approved for compliance after levy, and direct mail shipment can also be realized;
4. Support multi-store operation::Single-store declaration mode can be adopted to realize one account for one store, avoiding the audit risk caused by the confusion of accounts of multiple stores.Suitable for medium to large sellers with multi-platform and multi-store layouts.
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1. Businesses need to completeCross-border e-commerce filingThe company has obtained the right to import and export, and has completed the 9610/9810 model filing in the customs and tax departments;
2. Approved levies need to be applied for from the tax authorities and, after filing, tax returns are filed at the approved rate of profit, eliminating the need to provide cost invoices for non-billable purchases;
3. Need for reservationsPurchase screenshots, payment flow, logistics vouchers, platform operation records, etc., build the chain of evidence of the business to ensure the authenticity of the business;
4. Under the 9810 model, the goods need to complete the customs record after entering the overseas warehouse, and the subsequent sales data need to be synchronized to the regulatory system.Realize the traceability of the whole chain of "export - storage - sales".
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Shenzhen, an Amazon seller, the main kitchen small household appliances, annual sales of 30 million, there are five Amazon stores, the upstream suppliers are mostly small and medium-sized factories in Foshan, the proportion of non-invoiced purchases up to 70%, invoicing needs to be added to the 8% tax points, previously due to non-invoiced purchases can not offset the cost of the EIT tax burden as high as 25%, the annual payment of EIT of nearly two million dollars, but also received a tax warning!(12 consecutive months of single store sales over $5 million).
In 2025, this seller applies for 9810 model + approved levy (approved profit margin of 8%), no need to provide input invoices, and only pays EIT at a profit margin of 8%: 30 million x 8% x 25% = 600,000, saving 1.4 million in annual tax. At the same time, the seller retainsAll purchase flows, logistics bills of lading, Amazon back-office sales recordsIn addition, the seller has built a complete chain of business evidence and passed the subsequent verification by the tax department. In addition, the seller adopted the single-store declaration mode, with 5 stores accounting separately, avoiding the audit risk caused by the combined declaration of multiple stores, and also realized the sunshine collection of foreign exchange through the 9810 mode, bidding goodbye to the hidden dangers of the private account collection, and successfully expanded 2 new stores in 2026, with the annual sales exceeding 40 million.
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Medium to large cross-border sellers with annual sales of $20 million or more, a high percentage of non-ticketed purchases, and a focus on overseas warehousing (9810) or direct mail (9610), theEspecially good for AmazonWal-Mart and other mainstreamThe platform's big sellerIt supports multi-store and multi-category scale operations.
If you haveHong Kong Company Registration, Bank Account Opening, Annual Audit, Tax Audit, ODI Filing and Tax Complianceetc., 👉 Welcome to sweep the code to add our online customer service (micro letter: jxhqcy890 / cell phone: 16625410105), arrange for the manager to answer questions, provide professional advice and full one-on-one service!
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04.Model III: Direct purchasing by Hong Kong companies
For sellers who are purchasing without tickets and have cross-border layout needs, theHong Kong Company Direct ModeIt is a high-level solution for "non-invoiced procurement compliance", "tax optimization" and "platform operation compliance", especially suitable for sellers with annual sales of more than $50 million, multi-platform operation, or planning to do branding. It is especially suitable for sellers with annual sales of more than 50 million dollars, multi-platform operation or planning to do branding overseas.
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1. Avoiding Tax Risks of Domestic Uninvoiced Purchases::Using Hong Kong companies to purchase directly from domestic suppliers, Hong Kong's tax system is simple, no value-added tax, and only profits tax is levied.both (... and...)Offshore income can be claimed as tax freeNo need to worry about purchase invoices;
2. Significant scope for tax optimization::Hong Kong profits tax rate is only 16.5%, and after realizing the tax exemption of offshore income, the tax burden is substantially lower than that of the domestic; at the same time, the Hong Kong company, as the main body of the operation, can reasonably plan the cross-border capital flow and reduce the overall operating costs;
3. Avoiding platform affiliation risk::With a Hong Kong company as the main body of the platform store, it can realize main body isolation with the domestic company and circumvent the multi-store association audit, which is suitable for Amazon, independent station and other platforms with high compliance requirements for the main body;
4. Flexible flow of funds::Hong Kong has no foreign exchange control, cross-border collection and settlement of foreign exchange is more convenient, suitable for brands to go overseas, the need for global capital deployment of sellers.
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1. The need for compliance with the registration of Hong Kong companies, to complete theBank account opening, annual review, auditand other basic operations to ensure that the operation of the Hong Kong company is compliant;
2. In the case of direct sourcing by Hong Kong companiesPurchase contracts, payment flows, logistics bills of lading, etc. need to be retained.to ensure the authenticity of the transaction and to provide a basis for offshore tax exemption claims;
3. If there is an operating entity in China, the structure of the Hong Kong company and the domestic company should be properly segregated.Avoid mixing accounts and triggering tax audits;
4. Offshore tax exemption should be applied for from the Hong Kong Inland Revenue Department by providing a complete chain of business evidence to prove that the income is derived from overseas and there is no local business operation in Hong Kong.
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Guangzhou, a cross-border seller, the main beauty skin care products, annual sales of 60 million, the layout of Amazon, independent station dual platform, the upstream suppliers are mostly small and medium-sized beauty factories in Baiyun District, Guangzhou, the proportion of invoiced purchases of 80%, invoicing needs to be added to the 13% tax points, and the domestic company's multi-store operations, facing the risk of correlation. Previously, the seller due to non-invoiced procurement, the domestic company corporate income tax tax burden is high, but also worried about multi-store association by the platform penalty, do not dare to large-scale expansion.
At the end of 2024, the seller complied with the registration of a Hong Kong company, opened a Hong Kong bank account, used the"Hong Kong Company Direct Sourcing + Offshore Duty Free" Model: The Hong Kong company directly purchases from domestic beauty factories without invoices, and then sells the goods overseas, and all the income is offshore income, successfully applying for Hong Kong offshore tax exemption (no need to pay profits tax of 16.5%). At the same time, the seller registered a new Amazon store with the Hong Kong company as the main body, and realized the main body isolation with the domestic company store, completely avoiding the associated risks.
After the rectification, the seller not only solved the compliance problem of purchasing without tickets, but also saved the cost of domestic corporate income tax, invoicing tax points, etc., and saved more than 3 million in annual taxes, and the flow of funds is also more flexible (no foreign exchange control, no need to approve the collection and settlement of foreign exchange), and the sales volume of the independent station in 2025 exceeded 20 million, and the layout of the brand out of the sea was successfully realized.
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Medium and large sellers with annual sales of 50 million or more, a high percentage of non-ticketed purchases, plans to brand overseas, and multi-platform and multi-store operationsIn particularsuitSellers who build cross-border structures and optimize capital flows and taxes.
05.Mode 4: No independent customs declaration, treated as domestic sales for tax purposes.
If sellers are temporarily unable to land the above three models, or do not need a complex cross-border compliance structure due to business characteristics (e.g., small categories, niche platforms, highly volatile shipments), theDeemed domestic sales tax payment modelcan be used asTouting Compliance ProgramThe cost is a little higher, but you can say goodbye to tax risk and achieve base compliance once and for all.
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The so-called deemed domestic sales, i.e., sellers without invoices for the procurement of goods, due to the lack of formal cross-border export customs clearance, according to the domestic domestic sales business to pay value-added tax and enterprise income tax, although you need to bear a certain tax burden, but can realize the formal accounts, tax compliance, to avoid the risk of audit due to the lack of invoices for procurement without formal customs clearance triggered by the risk of audits.
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1. Simplest operation, no filing threshold::No need to apply for import and export rights, no need to record any cross-border e-commerce model, according to the domestic small and micro-enterprise standard tax declaration can be, suitable for novice sellers or sellers with unstable business volume;
2. Say goodbye to tax risks for good: Formal tax filing with complete accounting records, no tax alerts triggered by purchases without tickets, no formal customs declarations, and basic compliance is achieved;
3. Adaptation to niche scenarios::It is suitable for sellers who do niche platforms and small categories, with low shipment volume and no scale operation needs, without investing energy in building a complex compliance system.
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1. Bysmall scale taxpayermaybegeneral taxpayerStandard tax declaration, low VAT rate for small-scale taxpayers (currently 1%), and corporate income tax can be enjoyed by small and micro enterprises;
2. Although there are no purchase invoices, it is necessary to retain the purchase flow, logistics vouchers, platform sales records, etc., to ensure the authenticity of the business;
3. This model has no export tax exemption/refund policy, the tax burden is relatively high, only as a bottom-up program, not recommended for long-term use by medium and large sellers.
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Shenzhen, a cross-border novice sellers, the main niche pet supplies, annual sales of 3 million, the layout of a niche cross-border platform, shipments are extremely unstable (1-3 orders per month, the value of a single ticket of 50,000-100,000), the upstream suppliers for small processing plants, can not provide invoices, and sellers do not have the energy to apply for the right of import and export, filing compliance mode, worried about no ticket purchases by the auditing.
The seller chose the deemed domestic sales tax payment mode, declared tax according to small-scale taxpayers (VAT rate of 1%), enterprise income tax to enjoy the preferences of small and micro-enterprises (taxable income of 1 million or less at 2.5%). Although there is no purchase invoice, the seller retained all the purchase payment flow, logistics express sheet, platform sales background screenshots, built a simple chain of evidence of the business, tax declaration according to the actual sales declaration, the annual VAT payment of 30,000 yuan, corporate income tax 75,000 yuan, a total of 105,000 yuan, although there is a certain tax burden, but completely bid farewell to the compliance risk.
The seller stated thatAt present, the business scale is small, the operation of the deemed domestic sales model is simple, without the need to invest additional effort, and so on the subsequent annual sales of more than 5 million, and then upgraded to the 1039 model or 9610 approved collection model, both to take into account the compliance needs of the moment, but also to control the operating costs.
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Cross-border e-commerce newbie,Lower annual sales (under $5 million), sellers with inconsistent business, doing niche platforms/small categories, or as aTransition programs before other compliance models fall into place.
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The development of cross-border e-commerce has long entered the era of "compliance deep plowing" from "barbaric growth", and the procurement of no ticket is not an insoluble problem.Pick the right compliance model for you--Small and medium-sized sellers do not need to pursue complex cross-border structure, 1039 mode can achieve low-cost compliance; medium and large sellers to take into account the scale and risk prevention and control, 9610/9810 approved levy is the core choice; and there are brands to go overseas needs of large sellers, Hong Kong companies direct sourcing mode can achieve compliance and optimization of win-win; novice sellers Or small business sellers, as domestic sales model can be used as a transition, first to keep the bottom line of compliance.
Remember, compliance is never "one-size-fits-all" or "the more complex the better," but ratherMatch your supply chain, operating model and volumeThe first step is to make sure that you have a good understanding of the tax regulations. Instead of taking a chance and continuing to purchase without a ticket + buy a single export, it is better to take the initiative to land on the compliance mode, after all, in the current situation of tightening tax regulation.Compliance is the most core competitiveness of cross-border e-commerce sellers, and the only bottom line for long-term operationThe
If your organization is facing the challenge of purchasing without a ticket and doesn't know which compliance model to match, get it by private message!Exclusive cross-border tax compliance diagnosis, customized landing solutions for you to say goodbye to tax risks and expand with ease and compliance!
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Compliance transition is better sooner rather than later, the earlier the layout, the lower the cost, the more stable the development.
📌 If your business is in one of the following stages:
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We have the corresponding solutions and practical experience.
Cross-border e-commerce there are many ways to plan, organized a detailed cross-border e-commerce tax compliance manual PDF, if there is a need for the boss can find me to get free ~ 👉 Sweep the code to add our online customer service (micro-signal:jxhAna888), arranging professional managers to answer queries and provideFull Process Compliance ProgramOne-to-one service ↓↓↓
Cross-border e-commerce tax compliance pain points
1、 Two sets of accounts: the internal accounts are chaotic and lead to difficult assessment, while the external accounts are difficult to file tax returns due to tax evasion and tax evasion;
2. Low income from external accounts, difficulties in financing, investment, mergers and acquisitions and IPOs;
3, no ticket purchases, personal accounts in and out of large sums of money, suspected of money laundering, tax evasion boss sleepless nights;
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Compliant Overseas and Domestic Equity Structures for Cross-Border Enterprises
1、Build a good in-country structure, that is, tax-saving and compliance
2, must set up a Hong Kong company as well as good positioning
3、Use of Hong Kong company offshore tax exemption policy
4. How is the store company built?
5、Why do we need to do offshore investment filing?
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Cross-border e-commerce fiscal and capital rational planning
1. Normative design for procurement without and with tickets
2. Reasonable pricing of goods exported from Hong Kong companies to achieve both tax savings and compliance
3, the company structure flow, goods flow, financial flow, tax flow, capital flow, contract flow, bill flow reasonable planning management
4、 How to make cross-border e-commerce enterprises and bosses' income legal? How to plan for shareholders' dividends?
5. Need to share the cost of payroll for in-country employees
6、 Must do cross-border service tax-free record
You can find the answers to all these questions in this PDF!
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If you haveHong Kong Company Registration, Bank Account Opening, Annual Audit, Tax Audit, ODI Filing and Tax Complianceetc., 👉 Welcome to sweep the code to add our online customer service (micro letter: jxhqcy890 / cell phone: 16625410105), arrange for the manager to answer questions, provide professional advice and full one-on-one service!
