These are two different things; it\u2019s important to keep them separate.<\/p>\n\n\n\n Based on Qicaiying\u2019s recent practical experience serving a large number of cross-border sellers in Shenzhen, Guangzhou, Shanghai, Ningbo, and other locations, as well as the explicit statements in the latest Q&A document for 2026\u2014<\/p>\n\n\n\n The tax authority's stance on the Suntech model is one of partial acceptance.<\/p>\n\n\n\n Specifically:<\/strong><\/p>\n\n\n\n \u2714 <\/strong>Recognition of the single-entity, unified customs declaration approach used in the original Suntech model may serve as proof of the normal export of goods.<\/p>\n\n\n\n \u2714 <\/strong>Approve the mechanism whereby costs, expenses, and personnel are allocated among export companies and third-party operators within the Group based on revenue share<\/p>\n\n\n\n \u2718 <\/strong>We do not approve of the practice of consolidating all store revenues into a single entity (such as a Hong Kong company); we require each store company to file its tax return independently based on its revenue.<\/p>\n\n\n\n Simply put: There is nothing wrong with the structure itself, but the methods for pooling funds and filing reports must be adjusted.<\/p>\n\n\n\n In the past, under the Saiwei 1.0 framework, many sellers had their stores and companies uniformly file zero tax returns; all revenue was nominally attributed to a Hong Kong company, keeping their mainland tax filings formally in order.<\/p>\n\n\n\n This line of reasoning still had some room for maneuver during the Golden Tax Phase III era, but it won\u2019t work in 2026.<\/p>\n\n\n\n Data Penetration Capabilities of the Fourth Phase of the Golden Tax System<\/strong><\/p>\n\n\n\n Platforms (such as Amazon, Walmart, TikTok Shop, etc.) have already submitted sales data to the tax authorities as required. The tax authorities\u2019 system contains data on how much revenue your store\u2019s company generates on these platforms each quarter.<\/p>\n\n\n\n Zero tax reporting for the store\u2019s business + platform data showing several million in revenue = the system automatically flags it, and a risk notification is triggered.<\/strong><\/p>\n\n\n\n This isn't the tax authority specifically targeting you; it was triggered by an automatic system comparison.<\/p>\n\n\n\n The Three Actions Most Likely to Give You Away<\/strong><\/p>\n\n\n\n \u2718 <\/strong>The store\u2019s company has consistently filed zero tax returns, which is significantly inconsistent with the revenue reported by the platform.<\/p>\n\n\n\n \u2718 <\/strong>The Hong Kong company is merely a shell company for receiving payments; it has no staff, contracts, or actual purchasing or sales functions.<\/p>\n\n\n\n \u2718 <\/strong>Funds have flowed back from Hong Kong to the mainland, but there are no corresponding sales contracts or service fee agreements to support them.<\/p>\n\n\n\n Based on our actual communications with local tax authorities, the regulatory focus for 2026 can be summarized in three points:<\/p>\n\n\n\n The problem isn't with the Suntech model itself, but rather with its improper implementation.<\/strong><\/p>\n\n\n\n The problem isn't with the Hong Kong company itself, but rather with the lack of commercial substance.<\/strong><\/p>\n\n\n\n The problem isn't with the multi-store structure itself, but rather with the discrepancy between reported figures and actual revenue.<\/strong><\/p>\n\n\n\n In 2026, the tax authorities will be more inclined to recognize the overall cost structure of individual stores\u2014that is, the direction of Saiwei 2.0\u2014where each store operates as a separate entity with independent accounting, independent tax filing, and independent responsibility for its corresponding costs.<\/p>\n\n\n\n Use the following three questions to assess your current level of risk:<\/p>\n\n\n\n \u2753 Has your store\u2019s company reported its platform revenue?<\/strong><\/p>\n\n\n\n If you have been filing zero returns for an extended period, you should assess as soon as possible whether to file back taxes or apply for a fixed-rate tax assessment.<\/p>\n\n\n\n \u2753 Does your Hong Kong company have genuine purchase and sales contracts and bank statements?<\/strong><\/p>\n\n\n\n If a Hong Kong company is merely a bank account for receiving payments and has no business documentation, it must establish substantive operations as soon as possible.<\/p>\n\n\n\n \u2753 Are there corresponding purchase contracts and service fee agreements for your capital inflows?<\/strong><\/p>\n\n\n\n If there is no reasonable explanation for funds transferred from Hong Kong to the mainland, such transfers are likely to be deemed an unreasonable transfer of profits by related parties.<\/p>\n\n\n\n If you answer \u201cno\u201d to two of these three questions, we recommend conducting a comprehensive compliance assessment as soon as possible\u2014don\u2019t wait until you receive a notification from Risk Control to address the issue.<\/p>\n\n\n\n Scan the QR code to add a consultant and get a free one-on-one compliance assessment\u2014we\u2019ll cut to the chase and tell you exactly how to assess your situation right now.<\/strong><\/p>\n\n\n\n Cell phone: 18676749275<\/strong> \uff5c WeChat: qcygscszk<\/strong><\/strong><\/p>\n<\/blockquote>\n\n\n\n Q: The company behind the store has always filed zero tax returns. What should we do now?<\/strong><\/p>\n\n\n\n A: First of all, don\u2019t panic, and don\u2019t rush to file a supplementary tax return. The first step is to review historical platform revenue, cash flows, export data, and domestic tax compliance. If the domestic export company or operating company has already paid the corresponding taxes, you\u2019ll need to compile a chain of evidence to demonstrate that no tax revenue has been lost. If there is indeed a gap in tax filings, you should develop a corrective action plan in accordance with local tax regulations; the sooner you address the issue, the lower the cost will be.<\/p>\n\n\n\n Q: Is it actually okay to file a zero-report? Has the tax authority made a clear statement on this?<\/strong><\/p>\n\n\n\n A: The tax authority hasn\u2019t issued a blanket ban, but according to official guidance: the practice of consistently filing zero returns without corrections and waiting for risk control measures carries the risk of a tax audit, and the audit process may extend back to 2022. Cases flagged by risk control are generally not subject to retroactive audits; only cases subject to a tax audit may be audited retroactively and result in fines.<\/p>\n\n\n\n Q: Under what circumstances would tax evasion by related parties be deemed to have occurred?<\/strong><\/p>\n\n\n\n A: The key criteria are whether the Hong Kong company has genuine business substance and whether there is a loss of tax revenue for mainland China. If the Hong Kong company is merely a shell entity, and funds only flow into it without flowing out, or flow into mainland China without a contractual basis, it is likely to be deemed an improper transfer of profits through related-party transactions.<\/p>\n\n\n\n This article explains it very clearly: the Savi model isn\u2019t unusable, but how it\u2019s used\u2014and whether it\u2019s used well\u2014boils down to a single word: the line between compliance and non-compliance. What you really need isn\u2019t an answer to the question of \u201dcan or cannot,\u201d but a judgment that translates the tax authorities\u2019 actual stance into concrete guidance on how to run your business.<\/p>\n\n\n\n \u2714\ufe0f Real-Time Policy Analysis:<\/strong>Qicaiying maintains close communication with tax authorities in various regions and continuously monitors the actual implementation guidelines in each area. What we provide you with isn\u2019t just an interpretation of documents found online, but real-world feedback from frontline service counters in cities such as Shenzhen, Guangzhou, Shanghai, and Ningbo.<\/p>\n\n\n\n \u2714\ufe0f No fear-mongering, just practical advice:<\/strong>Is there really a risk associated with filing a zero-revenue tax return for your business, and if so, how significant is it?\u2014Our answer won\u2019t exaggerate the risk by claiming \u201dyou\u2019ll be audited tomorrow\u201d just to get you to pay. To be honest: we\u2019ll explain when it\u2019s safe, when you need to be vigilant, and when we recommend taking proactive corrective action.<\/p>\n\n\n\n \u2714\ufe0f Diagnose First, Then Act:<\/strong>We don\u2019t just tell you, \u201dYou need to change everything\u201d right off the bat. During a 30-minute phone consultation, we\u2019ll first assess your store\u2019s size, platform distribution, compliance status, and funding channels\u2014then we\u2019ll let you know whether you need to make changes, what to change, and how to go about it.<\/p>\n\n\n\n \u2714\ufe0f Practical Experience from Various Locations:<\/strong>Even for the same Savi model, the tax authorities in Shenzhen and Ningbo focus on different aspects; even for the same issue, risk control and audit departments handle it differently. The experience we\u2019ve gained across different cities and case types directly serves as your reference framework.<\/p>\n\n\n\n We have assisted thousands of cross-border sellers in Shenzhen, Guangzhou, Shanghai, Ningbo, and other cities with compliance assessments and structural adjustments. Scan the QR code to add a consultant and get a free consultation. Cell phone: 18676749275<\/strong> \uff5c WeChat: qcygscszk<\/strong><\/strong><\/p>\n<\/blockquote>\n\n\n\n Established in 2015 and headquartered in Shenzhen, Qicaiying Group specializes in providing one-stop financial, tax, and corporate compliance services to cross-border e-commerce companies and businesses expanding overseas. Its services include company registration in Hong Kong and overseas, bank account opening, cross-border financial and tax compliance, VAT\/EPR registration, bookkeeping services, and corporate identity planning. Having served over 10,000 companies to date, it is a trusted financial and tax compliance partner for cross-border sellers. Qicaiying Group provides business registration and related commercial and tax services for companies in the United States, Singapore, Japan, Thailand, Malaysia, Canada, Mexico, Brazil, UK companies, French companies, New Zealand companies, Vietnamese companies, Indonesian companies, Philippine companies, and Dubai companies, among others. We also provide corporate services for domestic company registrations in Hong Kong, Shenzhen, Guangzhou, Shanghai, Hangzhou, Beijing, and Hainan, including annual reviews and audits, bookkeeping and tax filing, Mandatory Provident Fund (MPF) contributions, information updates, bank account openings, ODI filings, BVI registrations, tax compliance, and cross-border e-commerce support and management services. Please feel free to contact me if you need assistance. \ud83d\udcf1 Mobile: 13045886252, \ud83d\udcac WeChat: qcy20251218<\/p>\n\n\n\n Is the SAIWEI model still viable? This is the question cross-border sellers have been asking most frequently lately.<\/p>\n The tax authorities have collected statistical forms on multi-store models, there are more and more notifications about audit-based taxation, and there are rumors that some competitors have been audited\u2026 Many business owners are starting to panic: Can I still use this business structure?<\/p>\n First, here\u2019s a straightforward answer:<\/p>\n The Suntech model hasn't been shut down, but your past practices may no longer be sustainable.<\/p>\n These are two different things; it\u2019s important to keep them separate.<\/p>","protected":false},"author":10,"featured_media":10926,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_yoast_wpseo_focuskw":"\u8d5b\u7ef4\u6a21\u5f0f\u73b0\u5728\u8fd8\u80fd\u7528\u5417\uff1f","_yoast_wpseo_title":"","_yoast_wpseo_metadesc":"","_yoast_wpseo_opengraph-title":"","_yoast_wpseo_opengraph-description":"","footnotes":""},"categories":[17,18,13,64],"tags":[1387,1002,238],"class_list":["post-10924","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-allguide","category-recomguide","category-guide","category-gf-tax-compliance","tag-1387","tag-1002","tag-238"],"yoast_head":"\n![\"\"](\"https:\/\/qcyboss.oss-cn-shenzhen.aliyuncs.com\/wp-content\/uploads\/2026\/06\/20260605152927366-1024x576.png\")
<\/figure>\n\n\n\nI. The tax authorities have not put a stop to the Savi model<\/strong><\/h2>\n\n\n\n
II. Why isn\u2019t the 1.0 approach working anymore?<\/strong><\/h2>\n\n\n\n
III. What is the tax authority\u2019s official stance for 2026?<\/strong><\/h2>\n\n\n\n
IV. Three Self-Assessment Questions: Where Do You Stand in Terms of Risk?<\/strong><\/h2>\n\n\n\n
\n
![\"\"](\"https:\/\/qcyboss.oss-cn-shenzhen.aliyuncs.com\/wp-content\/uploads\/2026\/03\/20260323160847384.jpg\")
<\/figure>\n\n\n\ncommon problems<\/strong><\/h2>\n\n\n\n
Qicaiying: Why Choose Us for Compliance Assessments?<\/strong><\/h2>\n\n\n\n
One-on-One Compliance Assessment\u2014No beating around the bush; we\u2019ll tell you straight up how to assess the situation right now.<\/strong><\/p>\n\n\n\n\n
<\/figure>\n\n\n\nAbout Enterprise Caiying Group<\/strong><\/h2>\n\n\n\n
![\"\"](\"https:\/\/qcyboss.oss-cn-shenzhen.aliyuncs.com\/wp-content\/uploads\/2026\/06\/20260601175102490-1024x576.png\")
<\/figure>","protected":false},"excerpt":{"rendered":"