In 2026, the compliance dividend period for the cross-border e-commerce cluster is completely over.Notice 15 data penetration, Golden Tax Phase IV full link comparison, and Customs + Tax + Foreign Exchange Joint Inspection.Let the past “multi-store zero declaration, funds outside the body cycle, Hong Kong shell collection” play, overnight from the “industry subterfuge” into the “audit disaster area”.

Why are the headline sellers dead set on 0110 + Hong Kong companies and rejecting the policy-encouraged 9810?

Why must the Safeway model be upgraded from 1.0 to 2.0?

How do store group sellers find a balance between compliance, cost, and risk?

Summary of this article:

I. Circular 15 + Golden Tax Phase IV, the store group enters the “Naked Age”

Secondly, why are the big sellers sticking to 0110 and not using 9810?

III. Safeway Model 1.0→2.0

IV. Guidelines for selecting a store group model

V. Shop Group Compliance in 2026 3 big mines

VI. Summarizing: The 2026 Law of Compliance and Survival for Store Groups

"one" radical in Chinese characters (Kangxi radical 1),Circular 15 + Golden Tax Phase IV, the store group enters the “Naked Era”

2025 Starting from October, the State Administration of Taxation (SAT) Circulars No. 15 and No. 17 officially came into force, and cross-border e-commerce regulation shifted from “spot checks” to “Penetrating full-link monitoring.”::

1. Mandatory reporting of Platform data (Bulletin 15)

• Amazon, TikTok, Temu, Sizzler and more!all mainstream platforms.Quarterly reporting of sellers to the IRS: Identity information, store URL, transaction flow, settlement amount, collection account.
• Core Impact:Transparency of all store revenues, fund flows, and subject affiliations.The past operation of “multi-store decentralization, zero-declaration, and extra-circularity of funds” no longer has any gray space. There is no longer any gray space for the past operation of "multi-store decentralization, zero declaration, and circulation of funds outside the body".

2. Four streams in one: customs + tax + foreign exchange + platform data cross-validation

• Platform flow ↔ Customs declaration ↔ Bank collection ↔ Tax declaration, the four streams must match exactly.
• System automatic warning: As long as there is declared income ≠ platform flow, declared amount ≠ actual foreign exchange settlement, store zero declaration ≠ platform high flow, directly triggering the audit.

3. 2026 Audit Priorities (IRD Mapping Sheet issued)

• Special verification of the Safeway model:Whether the Hong Kong company is a shell, whether the pricing of connected transactions is fair, and whether the repatriation of funds is compliant.
• 0110/9810 Authenticity of customs declarations:Whether there are false declarations, under-declarations and over-declarations, and multi-store consolidated declarations without reasonable basis.
• extraterritoriality用Credits:Amazon advertising rates, commissions, warehousing fees, etc. thatMulti-district tax bureausImplementation 15% Limited Deduction.Excesses are subject to back taxes.

In a nutshell: in 2026, store group sellers must give up the “fluke” and move from “form compliance” to “substance compliance.”

二,Why are the big sellers sticking to the 0110 and not the 9810?

1. 9810: Encouraged by policy but not available for clusters of stores

9810 Definition: overseas warehouse for cross-border e-commerce exports.One store with one main body, one store with one customs declaration, one store with one tax rebate, and one store with one set of accounts.

Store group fatal pain points:

• High number of stores(dozens - hundreds): each store is independent of customs clearance, tax return and accounting.Financial Cost ExplosionThe
• Amazon Associated Risks: One body, one store.Multiple subjects are prone to triggering associationsThe account security cannot be guaranteed.
• Difficulty in pooling funds::Multi-store funds are decentralized.Inability to harmonize management, rapid repatriation, reduction of exchange rate lossesThe

2. 0110: Uniquely adapted compliance channel for store groups

0110 Definition: General trade export, unified customs declaration, unified tax rebate and unified foreign exchange collection by one domestic company.

Store Core Strengths:

• Architecture Adaptation:Domestic company→0110 Export→Hong Kong company→Distribution of global storesIt is a perfect solution for multi-store associations, capital pooling and unified tax refund.
• Costs are manageable:1 set of accounts, 1 customs declaration, 1 tax refund, the management cost is only 1/10 of 9810.
• cash flow活::Hong Kong company unified collection, unified foreign exchange settlement, unified return, to avoid the risk of multi-store capital dispersion.

3. 0110 + Hong Kong company: standard structure for big sellers (most stable model in 2026)

Four-tier architecture (Safeway model standard):

• Domestic sales companies: Responsible for Procurement, 0110 Customs Clearance, Export Tax Refunds.
• Domestic operating companies:Responsible for advertising, customer service, logistics, and expense accounting.
• Hong Kong company (capital center): Uniform collection, funds pooling, secondary resale, profit retention.
• Store group companies (store shells):Only registered stores, no touching of funds, no declaration, attributed to Hong Kong companies through authorization agreements.

Conclusion: 9810 is suitable for single store / boutique sellers; 0110 + Hong Kong company is the only compliant way out for store group sellers.

surname San,Safeway Model 1.0 → 2.0: From “Zero Declaration” to “Substantial Compliance”, Life and Death Escalation

1. Safeway 1.0: once the standard for store groups, now dead

Core Logic: Zero declaration of store company, one-click capital pooling, Hong Kong shell retained profits.

Fatal risk (post-15):

• Platform data ≠ store declaration: store zero declaration, but the platform reports huge amount of water flow, directly triggering the audit.
• Hong Kong shell is penetrated: no office, no employees, no business, the IRD recognizes it as a pure conduit company, and profits need to be back-taxed in the territory.
• No basis for repatriation of funds: no ODI filing, no transfer pricing documentation, no legal repatriation of funds.

2. Safeway 2.0: The Only Compliant Answer for Store Groups in 2026

Core logic (offshore sourcing, offshore sales):

• Domestic company → 0110 Export → Hong Kong company (real purchases)
• Hong Kong company → secondary resale → various store companies (offshore transactions)
• Store Company → Amazon Sales → Reporting Revenue by Actual Sales (matching with platform data)

Three compliance breakthroughs:

• Stores no longer declare zero: consistent with the platform data, completely avoiding the risks of Circular 15.
• VAT exemption for offshore transactions: purchases and sales are all offshore, VAT exempt and the tax burden is manageable.
• Preserve the store group structure: no triggering of Amazon associations, funds pooling, unified tax refunds, and controllable costs.

3. 6 hard conditions that must be met for Safeway 2.0 (one or the other)

1. Hong Kong companies make it real:Renting office, hiring staff, doing audits, holding board meetings (annual cost of HK$150,000 - 200,000).
2. ODI Records:The official endorsement of the funds out of the country, back to the country, without the record can not be legally settled.
3. Transfer Pricing Documentation:: Functional risk analysis, comparable data, affiliation agreements (to demonstrate fair pricing).
4. The four streams are consistent:Contracts, logistics, funding, and invoices are fully matched.
5. Offshore cost compliance:Advertising, commission and storage fees are declared according to the IRS caliber.
6. Co-location:Cross-city registration is prone to tax source disputes, and co-location reduces the risk of audit.

Conclusion: Safeway 1.0 is dead, Safeway 2.0 is a must-have option for the store group in 2026.

四,Store model selection guide: by number of stores, annual sales, risk tolerance

1. Model comparison table (direct application)

2. Best option for 2026 (direct copy)

• <10 Stores / Annual Sales < 30 Million: 9810 (Simple, Compliant, Cost Controllable).
• 10-50 stores / annual sales of 30 million - 200 million: Safeway 1.0 (transition) → 2.0 (upgrade).
• >50 stores / annual sales > 200 million: mandatory Safeway 2.0 (the only way out of compliance).
• >100 stores / annual sales >500 million: local stores + Safeway 2.0 (double insurance).

五,2026 Store Group Compliance 3 Big Thunders

1. Offshore cost credits (biggest pitfalls)

• Status quo: Amazon advertising, commissions, and warehousing fees account for over 50%, pro forma invoices only.
• Risk: Many tax bureaus only recognize 15% deduction, overage is subject to back taxes.
• Solution: Communicate with IRS in advance, prepare third-party appraisal reports, contracts, and payment vouchers.

2. Substance of Hong Kong companies (audit focus)

• Risk: Shell Hong Kong companies are taxed through and through.
• Solution: Make a real Hong Kong company (office, staff, audit, board of directors).

3. Return of funds compliance (fatal point)

• Risks: No ODI filing, no transfer pricing documentation, no legal repatriation of funds.
• Solution: Complete ODI filing, create transfer pricing documentation, and sign affiliation agreements.

6,Summarizing: 2026 Store Group Compliance Survival Rules

• Give up the fluke: Circular 15 + Golden Tax Phase IV, data penetration without dead ends.
• Choose the right model: 9810 is suitable for small stores; 0110 + Safeway 2.0 is suitable for large store groups.
• Compliance: Hong Kong company substance, ODI filing, transfer pricing, four streams of consistency.
• Early Layout:April-June 2026It's the compliance window to complete the structural upgrade as soon as possible.

One last word: In 2026, store groups are not about who sells more, they are about who lives longer. Compliance is not a cost, it's a ticket to live.

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