Can cross-border e-commerce companies export to Hong Kong using the 0110 model?
Published: 2026-04-23
In 2026, when cross-border e-commerce regulation is tightening and margins are thinning, the0110 B2B2C Structure for General Trading + Hong Kong CompanyThe “optional program” has gone from being "optional" to being the standard for medium to large sellers of 60% and above.
It is both takingMaximum 13% Export tax rebateIt is also the core path to solve the collection and remittance compliance and avoid tax risks, and it is the compliance key for store group sellers to break through the “one subject, one store” restriction.
Summary of this article:
I. Underlying logic: 0110 mode, more than just customs codes
II.2026 Mainstream Architecture Disassembly: 3 Scenarios to Adapt to Different Sellers
Third, the operation of the whole process: 5 steps to the ground, four streams of unity
Fourth, 2026 compliance red line: 4 major minefields absolutely can not be touched
V. Deep value: from “earning tax rebates” to “building barriers”
VI. Summary: 2026, Compliance is Survival
"one" radical in Chinese characters (Kangxi radical 1),Underlying Logic: 0110 Mode, More Than Just Customs Declaration Codes
0110 = General trade exportsThe customs control code 0110, the core of which is the territory of theEnterprises with import and export rights in China → buyers from overseas enterprisesThe B2B transaction, which requires four flows (contract flow, goods flow, capital flow, and invoice flow to match exactly).
Why cross-border B2C sellers must marry a Hong Kong company?
0110 model strictly prohibits direct selling to C-end consumers, and the offshore consignee must be an enterprise. Hong Kong companies as the “offshore purchasing body” to build the Domestic export company → Hong Kong company (B2B) → Overseas consumer (B2C)The closed loop, perfectly adapted to regulatory requirements, while unlocking three core values:
Tax rebate dividend:Up to 13% export tax rebate, annual sales of 10 million can save 910,000 cash flow;
Tax optimization:There is no VAT in Hong Kong and the tax rate for the first 2 million profits is only 8.25%, while non-Hong Kong sourced income is tax exempt;
Freedom of funds:Hong Kong account receives and pays global currencies without restriction, the goods flow back in compliance, to avoid the risk of underground money changers.
二,2026 Mainstream Architecture Teardown: 3 Scenarios for Different Sellers
1. Multi-store pooling model (Safeway 1.0, most mainstream)
Architecture:Domestic export company (unified purchasing / customs clearance / tax refund) → Hong Kong company (receiving goods / payback) → multi-platform store (sales body only);
Advantage:Proven process, lowest cost, correlation-proof, and suitable for sellers with 10+ store clusters;
Risks:Discrepancies between store zero declarations and platform data can easily lead to tax inquiries.
2. Hong Kong company resale model (Safeway 2.0, high compliance)
Architecture:Domestic export company → Hong Kong company → Domestic store companies (independent declaration of sales);
Advantage:The data is fully matched to resolve tax differences and meet the platform's “single store independence” requirements;
Applicable:Medium to large sellers with 3-5 stores and strong compliance needs.
3. Local store model (deep overseas)
Architecture:Hong Kong companies → overseas local companies → local consumers, adapting to target market compliance;
Advantage:Proximity to markets, lower tariffs, and increased user trust.
surname San,Practical operation of the whole process: 5 steps to land, four streams of unity
1. Preparation of qualifications (one without the other)
Domestic: Import and export license + General taxpayer status + Customs registration + Tax refund filing;
Hong Kong: Real Registration (Business Registration Certificate + Articles of Association) + Local Director + Fixed Address, Empty Shell is strictly prohibited.
2. Transaction structuring
Signing of sales contract for domestic exporters ↔ Hong Kong companies (specify name / quantity / price);
Signing the agreement for the domestic operating company to operate on behalf of Hong Kong company ↔ Domestic operating company (specify the service fee).
3. Customs clearance and logistics
0110 Customs declaration, submission: customs declaration, contract, invoice, packing list, bill of lading;
Goods can be shipped directly to FBA / Overseas Warehouse, no need to transit through Hong Kong, the consignee of the customs declaration fill in the Hong Kong company.
4. Compliant repatriation of funds
Overseas consumer payment → platform → Hong Kong company's public account;
The Hong Kong company pays the payment to the domestic exporting company, pays the service fee to the operating company, and settles the payment on a public-to-public basis;
Foreign exchange write-off: the following year before April 30 to collect foreign exchange can be, no 180-day limit.
5. Tax filing (core compliance)
Domestic tax rebate: from the month following the customs declaration to the declaration before April 30 of the following year, with the customs declaration, special invoice for imported goods and water bill for remittance collection;
Hong Kong tax return: licensed accountants audit, the first 2 million profit 8.25%, zero declaration is strictly prohibited.
四,2026 Compliance Red Lines: 4 Minefields You Can't Touch
1. Hong Kong company with no business substance (highest risk)
Shell companies without local directors/addresses/businesses will be recognized as false trade and will be subject to recovery of tax refunds, tax reimbursement for deemed domestic sales, late payment fees, and credit downgrading.
2. Inconsistency of the four streams (focus of scrutiny)
Name / Quantity / Unit / Amount mismatch, wrong HS code, incomplete documents, direct tax refund failure + customs penalty.
3. Abnormal return of funds
Underground money laundering, personal account turnover, bogus service fees, triggering FX audits + account freezes + criminal liability.
4. Export on purchase order (total phase-out)
No real customs declaration, borrowing other people's qualifications, 2026 full chain penetration supervision, once the investigation is confirmed, the legal person loses trust + enterprise bankruptcy.
五,Deep value: from “earning rebates” to “building barriers”
1. Profit restructuring: tax rebates as a core competency
Example: the value of goods 10 million, the cost of 7 million, the tax rebate rate of 13%, tax rebate of 910,000, the overall tax burden from 11.59% to 3.75%, directly crushing the non-refundable competitors.
2. Compliance Moat: Avoiding 90% Tax Risks
Say goodbye to the “gray area”, 4 streams in one + Hong Kong audit + domestic tax payment, withstand customs / tax / foreign exchange penetrating check.
3. The global springboard: from cross-border seller to international enterprise
As a capital and operation center, a Hong Kong company can freely deploy global capital, expand multiple markets, reduce exchange rate risks and pave the way for listing.
6,In Summary: 2026, Compliance is Survival
0110 + Hong Kong company is not “optional”, but a must-answer question in the era of tighter regulation and thinner profits. It solves the three major pain points of tax rebate, foreign exchange collection and compliance with a mature structure thatBuild long-term barriers with the tax and capital advantages of a Hong Kong company.
return (to a previous condition)[0110 Compliance] [Hong Kong Company Registration]We will arrange a tax consultant to do a one-on-one risk diagnosis for you free of charge and generate a 2026 Cross-border E-commerce Compliance and Rectification Program exclusively for you.
Contact: kuajinghg001
The article is for reference only, please consult your professional advisor for details
Tags:
0110 mode
Import and export customs clearance
four streams in one
Hong Kong Company Structure
0110 General trade
Import and export tax rebates
Cross-border e-commerce fiscal compliance
cross-border e-commerce
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