At a time when cross-border e-commerce compliance is all the rage, the9810 Overseas warehouse stocking export modelThe 9810 model is officially defined as the core development direction of cross-border e-commerce export. Compared with the traditional general trade, 9810 mode is suitable for cross-border sellers“ core business logic of ”first stocking overseas, then retailing online", which perfectly fits the refined operation scenario of overseas warehouses.

However, looking at the current situation of the industry, even if the policy has been in place for many years, the vast majority of cross-border sellers are still cautious and wait and see, do not dare to large-scale landing use.

The root of the problem:9810 There is only a unified policy framework, but no nationally standardized standards for implementation on the ground.Customs pricing, invoicing rules, revenue recognition, cost deduction, capital pooling, compliance definition of the six core aspects of the existence of a large number of practical BUG, tax, customs supervision around the caliber of the different, to the seller to bring a very high financial and tax risks.

Today, we are going through theSix Soulful Questions for Industry PracticesIn addition, the 9810 model's compliance truth, practical difficulties and pit avoidance guide are dismantled in depth, giving all cross-border sellers who layout overseas warehouses a complete compliance reference.

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• Customs Pricing:GMV, payback, cost price, who really counts?
• Export invoices:The double problem of invoicing subject and amount, no solution to the dilemma
• Revenue Recognition:There is a complete disconnect between accounting, tax, and business logic.
• Cost Credits:Restricted offshore expense deductions squeeze sellers' profit margins
• Funds are pooled:Compliance and efficiency can't be reconciled under the three-stream alignment constraints
• Compliance Essence:Applying the 9810 code ≠ 100% compliance

"one" radical in Chinese characters (Kangxi radical 1),Customs pricing: GMV, payback, cost price, who really counts?

9810 The core feature that distinguishes trade from traditional trade is theShip first, sell laterThe goods have not yet generated a terminal order when they leave customs and are shipped to overseas warehouses. When goods are declared for customs clearance and shipped to overseas warehouses, terminal orders have not yet been generated, which leads to a natural inconsistency in the data of declared value of goods, platform sales GMV, and actual bank returns, and is the root of all 9810's financial and tax problems.

At present, the national tax system has no uniform declaration standard, all rely on the local tax bureau supervision caliber implementation, the three declaration methods on the market have obvious disadvantages:

1. Reporting by platform sales (GMV)

The declared amount is an estimated value, which cannot match the subsequent real sales situation. And there is inventory backlog, discount promotion, return, etc. after the goods leave the sea, which will lead to a serious disconnect between the customs declaration data and the platform push tax data. At the same time, the estimated sales are on the high side, which is very easy to trigger the risk of customs verification and inspection, and there is no clear specification for the write-off of the difference in the amount generated by the platform deduction.

2. Declared on the basis of actual bank returns

This method is close to the real cash flow of the enterprise, the income tax accounting is more accurate, and it can avoid the controversy of offshore expense deduction. However, the return belongs to the net income after deduction of commission, advertisement, warehouse rental and logistics, and the difference with the platform GMV is extremely large, without the support of professional system, the enterprise manpower can't complete the work of massive data reconciliation.

3、Declare at FOB cost + estimated profit

This is a commonly used suggestion program for freight forwarders, but the practicality is extremely low. Goods are not completed terminal sales, profits can not be accurately predicted, belongs to the theoretical feasible, ineffective way to land.

Essential Summary:9810 declared price was never a problem at the level of the declaration, theAt the core is the lack of fiscal standards for corporate revenue recognitionIn addition, there is a need to improve the tripartite policy of customs, taxation and foreign exchange in a coordinated manner.

二

Export invoices: the subject of invoicing, the amount of the double problem, no solution to the dilemma

Referring to the traditional 0110 general trade model, the export invoice is the core document for tax refund, foreign exchange verification and fiscal traceability.Therefore companies under the 9810 model must issue export invoices. But copying traditional trade invoicing rules triggers two major industry pain points that cannot be circumvented.

On the one hand, the amount invoiced is difficult to define.Invoicing according to the amount of customs declaration will generate a difference with the real sales data of the platform, and there is no uniform implementation standard for subsequent red flushing and re-invoicing; invoicing according to the sales of the platform will lead to a disconnection between customs declaration and invoicing data, and the traceability significance of the export invoices will be completely lost.

On the other hand, the subject of invoicing is vague.In terms of business substance, 9810 is a typical B2C retail model, where goods are ultimately sold to overseas end-consumers rather than e-commerce platforms such as Amazon.

However, the monthly order volume of cross-border sellers is often tens of thousands, one by one to the C-end consumer invoicing, matching orders and input vouchers, the cost is extremely high, the workload is huge. Therefore, most of the industry chooses to invoice to the platform.Yet there is a compliance risk that the substance of the business does not match the body of the note.

surname San,Revenue recognition: a complete disconnect between accounting, tax and business logic

Revenue recognition time, is the 9810 model of the biggest fiscal bugs, but also the biggest differences in the supervision of the local tax bureaus, the three major dimensions of the rules are completely cut off.

In terms of accounting standards: Goods are only stored in overseas warehouses, not completed terminal sales, the control and risk of goods have not been transferred, there is no need to recognize revenue, and only overseas warehouse inventory can be accounted for.

From the EITC rules:Following the principle of real business, revenue can be recognized only after the completion of end-consumer sales, and customs clearance and departure are not equal to sales landing.

From the VAT refund rules:It is required to complete the processing of tax exemption and tax refund in the month when the goods are exported, and to implement the model of “tax refund upon departure and accounting for sales”.

The policy level of “refund before verification” poses a significant tax recovery risk to the IRS.Therefore, the majority of tax bureaus across the country have suspended the pre-refund policy to avoid the risk, and have adopted the conservative supervision method of “refunding the tax after the completion of sales”.

Up to now, some tax bureaus recognize “recognition of revenue after terminal sales”, while some require “recognition of revenue upon customs clearance”, and the difference in the calibre of the territories directly determines the way of financial and tax treatment of the enterprises, with no uniform standard answer.

四,Cost deduction: limited deduction of offshore expenses, squeezing sellers' profit margins

According to the Enterprise Income Tax Law, reasonable expenditures truly incurred by an enterprise and related to revenue can be deducted before tax, regardless of whether they are domestic or foreign. Theoretically, cross-border sellers' offshore costs, such as platform commissions, advertising, overseas warehouse rentals, and cross-border logistics, are all eligible for compliance deduction.

However, in practical scenarios, sellers generally face two major deduction challenges:

First, voucher recognition is low.There is no uniform VAT invoice for cross-border business, and most of them rely on platform settlement statements, overseas service providers' bills and payment flows as vouchers, and the degree of recognition of such non-standard vouchers by different tax bureaus varies.

Second, there is a credit limit.Most tax authorities follow the general fiscal rules and limit the deduction of advertising and business promotion expenses to a maximum of 151 TP3T of annual sales revenue, and the deduction of fees and commission expenses to a maximum of 51 TP3T.

For the cross-border e-commerce industry, which has a net profit of only 5%-15%, the cost of operating outside the country takes up a large part of the total cost.Costs cannot be fully deducted before tax, which will directly lead to a soaring corporate tax burden, and even a loss situation in which profits cannot cover taxes, which is the core pain point of the industry-wide call for 9810 policy optimization.

五,Funds Pooling: Compliance and Efficiency Cannot Be Combined Under the Three Streams of Consistency Constraints

Funding control is the core issue that cross-border sellers are most concerned about. Compared with the traditional 0110 trade model, which can flexibly pool global funds and unify the advantages of scheduling and control, the 9810 model's capital rules greatly limit the seller's operational efficiency.

The core bottom line of 9810 compliance is that the main body of store entry, the main body of customs clearance and export, the main body of foreign exchange collection, and the main body of tax rebate must be completely consistent to realize the three streams of closed loop.

This means that sellers with a multi-store matrix must file customs declarations store by store, collect foreign exchange store by store, and refund taxes store by store.Not only will it lead to exponential rise in customs clearance, logistics, agency and labor costs, all the store funds are scattered in different subject accounts, the fund scheduling efficiency is extremely low, and at the same time, there is a potential risk of account risk control and fund loss.

Some sellers choose to centralize a single company to file a unified return in order to compress costs, which improves operational efficiency but causes serious inconsistencies between multi-store sales data and single filing data, and a large number of enterprises have been suspended from tax refunds as a result, with extremely high compliance risk.

6,The essence of compliance: applying the 9810 code ≠ 100% compliance

Many sellers have cognitive misunderstanding: as long as the 9810 customs clearance channel, the enterprise will complete the financial and tax compliance. However, from the perspective of tax supervisionRegulatory codes are never the compliance standard, business authenticity is theThe

The IRS verification of 9810 compliance will only focus on three main cores:

1. Whether the flow of goods, sales and capital is complete and closed loop, with no breaks or anomalies;
2. Whether the full set of vouchers such as contracts, customs declarations, logistics waybills, overseas warehouse receipts, platform settlement bills, etc. are complete and traceable;
3. Whether all sales orders of the enterprise are truthfully declared, taxes and fees are paid in full, and there is no hidden income or false customs declaration.

Write at the end:

Undoubtedly, 9810 overseas warehouse mode is the future trend of cross-border e-commerce export compliance, and is also a new mode of cross-border trade that the state focuses on supporting. However, objectively speaking, the policy is still in the stage of figuring out the landing, the rules of customs, taxation and foreign exchange have not yet been opened, the national unified practical standards are missing, and the overall compliance soil is not mature.

For cross-border sellers, blindly testing the waters of 9810 is very likely to trigger the suspension of tax refunds, tax audits, freezing of funds and other risks.

Hands-on advice to all sellers:

• Compliance front: before landing 9810, communicate in depth with the competent local tax bureau in advance, and take the local official caliber as the only implementation standard;
• Do not pilot blindly without the support of professional tax and customs team and digital system;
• Steady as we go: Prioritize the consolidation of basic financial and tax compliance, sort out business credentials, improve the three streams of data, and wait for the maturity of the policy system to be gradually laid out.

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