In the recent month, a large number of Amazon / Overseas Warehouse sellers in Shenzhen, Guangzhou and Yiwu encountered the same nightmare:

0110 Customs declaration → tax refund rejected → make up information → rejected again → tax delayed → cash flow is dragged alive.

Many sellers are confused: they used to report like this all the time and could be refunded; now they suddenly can't? In the end, is the tax bureau stuck strict, or customs broker messy report, or their own business model itself is “non-compliance”?

Today to put words thoroughly: 2026, overseas warehouse stocking with 0110 customs declaration, the essence of the “business counterfeiting”, tax rebates are rejected is inevitable, the future will also be involved in the income tax, foreign exchange, gold tax four big data audits.

"one" radical in Chinese characters (Kangxi radical 1),Case in point: $3 million in tax refunds got stuck because of a wrong code.

📌 A boutique Amazon seller in Shenzhen, doing North American home category, annual sales of 200 million +, has been using Hong Kong company structure:

• Domestic companies → Hong Kong companies → Amazon FBA
• Customs clearance: 0110 General trade
• Tax refunds: previously normal refunds, starting to slow down at the end of 2025, and outright “non-refundable” in 2026”

The reason given by the IRS is very short but deadly:

“0110 The business logic does not match the actual overseas warehouse, and the three streams of cargo right, collection and contract are contradictory, so no tax refund will be granted.”

The seller is dumbfounded: the contract, invoice, bill of lading are complete, how is “logical inconsistency”?

There is only one core answer:

0110 is “first transaction, then export”; overseas warehouse is “first export, then transaction”. The business models are completely opposite, and using the same set of customs clearance logic is hard in itself.

二,What exactly is exempted from the no-ticket tax exemption?

In-depth teardown: 0110 vs 9810, the difference is not just a code, it's “legal characterization”

1) 0110 (General Trade): Traditional B2B, Departures = Sell-offs

• deedaffairlogic (loanword)::Sign a contract, set a buyer, set a price, then export
• cargo right: Cargo leaving China.The rights to the goods are immediately transferred to the offshore buyer.
• foreign exchange collection (finance): Amount declared = amount contracted = must be recovered in full, not a penny less.
• tax rebate or refund: “Export + Sales + Receipt of Foreign Exchange” must be completed in 3-6 months.
• be applicable: Factory→Overseas company, traditional B2B, with real overseas procurement contract

a line of verse话::0110 = The goods are sold and the money must be recovered in full.

2) 9810 (cross-border e-commerce export overseas warehouse): overseas warehouse stocking, departure ≠ transaction

• business logic::Prepare for export first and sell on the platform later
• cargo right: Shipments to FBA / Third Party Overseas Warehouses.Ownership remains with you until the terminal is sold
• foreign exchange collection (finance): Allow the rolling difference settlement, the return can be higher / lower than the amount of customs clearance, in line with the actual situation of the platform commissions, advertising fees, returns, etc.
• tax rebate or refund: Pre-refund upon departure, most of the tax is refunded first and then cleared on the basis of the actual sales, which is very efficient in terms of capital.
• be applicableAmazon FBA, third-party overseas warehouse, self-built warehouse, B2B2C mode

in short::9810 = stock up on goods, sell them slowly, get your money back slowly, the difference is reasonable.

3) Fatal contradiction: using 0110 for overseas warehousing is tantamount to “faking B2B transactions”

Tax / Customs / OFAC is now a four-way data matching network:

• customs (i.e. border crossing inspection):: 0110 = Departure sale
• flat-roofed building: You have a store, orders, and buyers on Amazon!
• foreign (currency) exchange: Amount of return ≠ amount of customs declaration, perennial difference
• taxation services: Golden Tax Phase IV direct comparison platform revenue, export data, input invoices

Conclusion:Overseas warehouse + 0110 = contradictory business logic, the moment the data is compared, it will be revealed, and the tax refund is stuck is just the first step.

surname San,Three stealthy minefields in 2026: Tax refunds are just “appetizers”

⚠️ minefield 1: tax refund is rejected, but also treated as domestic sales to make up 13% tax

Many sellers think “if you can't return it, forget it”:

• 0110 Declaration.the substance of the business is not established.Taxes can directly determine “false exports”
• Processing results:Non-refundable + deemed domestic sales + 13% VAT + late payment fee
• Large sellers lose far more than the tax refund itself

⚠️ Minefield 2: Long-term foreign exchange differences, focused on by the OFAC

0110 Requires full collection and one-to-one correspondence, but the overseas warehouse is actual:

• Customs clearance FOB price < platform selling price
• Platform deductions for commissions, advertising and storage fees
• Returns, obsolescence, destruction
• Actual return ≠ declared amount, perennial difference

2026 New Deal on Foreign Exchange:Large, long-term difference accounts are placed directly on the “key monitoring list”, which affects all receipts and payments of remittances.

⚠️ minefield 3: Golden Tax Phase IV + platform data direct connection, income tax remittance hiding a big mine

Now the tax office can get it directly:

• Amazon / Walmart and other platforms store revenue data
• Customs export declaration data
• Enterprise input invoices, cost data

Overseas Warehouse + 0110 is bound to appear:

• Customs declaration revenue < actual platform revenue
• Cost-sharing confusion, broken bill chain
• Multi-store, multi-principal, complex capital transactions of Hong Kong companies

2026 Income tax remittance: if there are large data discrepancies that cannot be reasonably explained, directly authorized levy + additional tax + penalty.

四,2026 Compliance Only Solution: Overseas Warehousing Must 9810

(1) Policy level: the state clearly supports 9810, 0110 is no longer adapted to cross-border e-commerce

• General Administration of Customs: 9810 is the only exclusive regulatory code for overseas warehouse preparation
• General Administration of Taxation: 9810 Implementation of the departure-on-pre-refund tax, a significant increase in financial efficiency
• OFAC: 9810 allows rolled over collection of foreign exchange, fully matching the actual return of the platform

2) Operational level: 9810 is not “optional,” it's “mandatory”

Suitable for 9810 scenarios:

• ✅ Amazon FBA Backup
• ✅ Third Party Overseas Warehouse (US / Europe / Japan)
• ✅ Own Overseas Warehouse
• ✅ B2B2C model (stock up and sell later)

Not suitable for 9810 scenarios:

• ❌ Real traditional B2B (factory → offshore company)
• ❌ Fixed contracts in place, clear buyers, locked in price

3) 9810 Core Strengths (2026 latest)

• ✅ Advance tax refund upon departure with shorter funding cycle 70%+
• ✅ Allow roll over collection of foreign exchange to settle the difference in platform commissions and advertising fees
• ✅ Logical consistency of goods rights, customs / tax / foreign exchange tripartite approval
• ✅ Support single-store closure without complex Hong Kong architecture

五,0110 to 9810, 5 practical issues that sellers are most concerned about

Q::If I transfer 9810 now, will my old accounts from the previous 0110 be checked?

A: In 2026 the focus is on new business compliance, but large, long-term abnormal differences may still be traced. It is recommended to complete the model switch as soon as possible, standardize new orders and gradually digest old accounts.

Q::Can I do 9810 without a Hong Kong company?

AYou can do this: 9810 does not require an offshore entity, the domestic company directly declare customs and export to the overseas warehouse, bound to the corresponding platform stores can be.

Q::9810 What information is required for a tax refund?

A: Customs Declaration (9810), Input Invoice, Overseas Warehouse Receipt / Warehouse Receipt, Platform Store Information + Order Data, Logistics Bill of Lading.

Q::Can you do 9810 refunds nationwide?

A: At present, mainstream cross-border cities such as Shenzhen, Guangzhou, Shanghai, Ningbo and Xiamen have fully landed; some second-tier cities need to confirm the caliber of practice with the local tax bureau in advance.

Q::Store Group / Multi-Store Seller, 9810 How does it work?

A: Single-store closure is the trend: one domestic subject corresponds to one store, and customs declaration, foreign exchange collection, and tax refund are matched one by one; the 2026 income tax policy also supports reasonable cost sharing and solves the problem of multi-subject bills.

6,In 2026, compliance is not a question of choice, it's a question of survival

Any policy dividend has a corresponding risk boundary. The following are the generally recognized high risk points of the 9610 model across the realm, which must be avoided in advance:

• 0110 + Overseas Warehouse = Past Tense: Tax Refund Obstruction, Foreign Exchange Abnormalities, Golden Tax IV Audit Risks Triple-Plagued
• 9810 + Overseas Warehouse = Present + Future Tense: Efficient policy-supported tax refunds, flexible foreign exchange collection, and self-consistent data collection.

One sentence summary:

Overseas warehouse preparation, choose the right code, tax rebate smooth, capital security, compliance without worry; choose the wrong code, tax rebate stuck, the risk of accumulation, at any time the explosion.

2026, cross-border e-commerce has said goodbye to “barbaric growth” and entered a new era of “data transparency, regulatory networking, and compliance”.

return (to a previous condition)[9810 Compliance][Hong Kong Company RegistrationWe 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.