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<\/figure>\n\n\n\n01 Policy Background: With Tighter Regulations, Cross-Border E-Commerce Enters an Era of \u201cLook-Through\u201d Compliance<\/mark><\/strong><\/p>\n\n\n\n In recent years, the role of cross-border e-commerce in China\u2019s foreign trade landscape has continued to grow. According to data from the General Administration of Customs, the value of China\u2019s cross-border e-commerce imports and exports exceeded 2.6 trillion yuan in 2024, representing a year-over-year increase of 14.8%.<\/p>\n\n\n\n Amid rapid economic growth, some enterprises have engaged in practices such as issuing fraudulent invoices, export transactions based on purchased invoices, and non-compliant capital repatriation, posing risks to tax administration and international creditworthiness. Announcements No. 15 and No. 17 represent key measures taken by regulatory authorities to implement \u201cdata-driven tax administration and transparent oversight\u201d:<\/p>\n\n\n\n \u25aa Announcement No. 15: Requires internet platform companies to regularly report tax-related information\u2014such as revenue, orders, and commissions\u2014for businesses operating on their platforms, thereby enabling a comprehensive understanding of the scale of e-commerce businesses\u2019 operations.<\/p>\n\n\n\n \u25aa Announcement No. 17: Further optimizes the corporate income tax advance payment filing system, clarifies the tax filing and tax refund requirements for enterprises engaged in agency exports, consignment exports, and the production and sale of export goods during the export process, and standardizes tax administration for the export process.<\/p>\n\n\n\n In other words, once the policy is implemented, the revenue, costs, and profits of cross-border e-commerce companies will all be subject to thorough scrutiny, marking the industry\u2019s official entry into a new phase of \u201cstrict regulation and high transparency.\u201d<\/p>\n\n\n\n 02 Key Points of Announcement No. 15: Enhanced Reporting Obligations for Platform Operators<\/mark><\/strong><\/p>\n\n\n\n The core of Announcement No. 15 is that platform companies must submit business data on merchants operating on their platforms, including but not limited to:<\/p>\n\n\n\n \u25aa Revenue Information: Includes transaction volume, commissions, platform subsidies, advertising and promotion expenses, etc.<\/p>\n\n\n\n \u25aa Order Volume: Includes the number of completed orders, the number of return orders, the percentage of cross-border orders, and more.<\/p>\n\n\n\n \u25aa Business operator identification information: such as corporate or sole proprietor status, taxpayer identification number, etc.<\/p>\n\n\n\n This means that small and medium-sized cross-border sellers, who previously relied on platforms to \u201chide information,\u201d will gradually lose their \u201cregulatory blind spots.\u201d<\/p>\n\n\n\n Impact Analysis:<\/p>\n\n\n\n \u25aa Increased pressure on small sellers: The practices of \u201cpersonal payment collection\u201d and \u201ccollection and payment on behalf of others,\u201d which they relied on in the past, are no longer sustainable.<\/p>\n\n\n\n \u25aa Increased compliance costs for large sellers: They must verify the accuracy of their revenue and ensure consistency in their tax filings in advance.<\/p>\n\n\n\n \u25aa Greater platform responsibility: Leading e-commerce platforms (such as Alibaba International, JD Worldwide, SHEIN, etc.) must assume the role of \u201ctax information reporter.\u201d<\/p>\n\n\n\n Key Points of Announcement No. 03-17: More Refined Advance Payments and Tax Refunds at the Export Stage<\/mark><\/strong><\/p>\n\n\n\n Announcement No. 17 primarily addresses corporate income tax and tax refund issues in the export chain and clarifies the obligations of three categories of enterprises:<\/p>\n\n\n\n \u25aa Export agents: Must truthfully declare export agency business; issuing false invoices or filing declarations on behalf of others is prohibited.<\/p>\n\n\n\n \u25aa Entrusted export enterprises: Must provide a complete entrustment agreement, export contract, and proof of foreign exchange receipts and payments to ensure compliance with tax refund filing requirements.<\/p>\n\n\n\n \u25aa Manufacturing, sales, and export enterprises: These enterprises should file accurate declarations based on their actual production, sales, and foreign exchange receipts, thereby ensuring consistency among invoices, foreign exchange receipts, and tax refunds.<\/p>\n\n\n\n Impact Analysis:<\/p>\n\n\n\n \u25aa The export tax rebate cycle may be extended, so companies need to strengthen their invoice management and cash flow coordination.<\/p>\n\n\n\n \u25aa The \"buy-and-ship\" export model has been virtually eliminated; companies must now declare their exports through compliant export channels.<\/p>\n\n\n\n \u25aa Cross-border sellers using the \u201coverseas warehouse + B2B2C\u201d model should pay special attention to aligning foreign exchange receipt timelines with tax refund processing.<\/p>\n\n\n\n 04 Analysis of the Four Major Compliance Models for Cross-Border E-Commerce Under the New Policies<\/mark><\/strong><\/p>\n\n\n\n Under the combined regulatory requirements of Announcements No. 15 and No. 17, cross-border e-commerce businesses need to reassess their business models. The following four models are currently common and relatively compliant options.<\/p>\n\n\n\n \u25cf 1. The 1039 Market Procurement Trade Model<\/p>\n\n\n\n Scope of Application: Small and medium-sized cross-border e-commerce businesses with a shipment value of \u2264$150,000 per shipment.<\/p>\n\n\n\n Features:<\/p>\n\n\n\n \u25aa Procured from and exported via state-designated market clusters<\/p>\n\n\n\n \u25aa Exports are exempt from value-added tax, resulting in low demand for input invoices<\/p>\n\n\n\n \u25aa Settlements can be made through personal foreign exchange accounts, and foreign currency receipts from multiple parties are supported<\/p>\n\n\n\n Advantages: Simplified customs clearance procedures and flexible payment terms.<\/p>\n\n\n\n Disadvantages: Limited to specific markets; order value is modest; not suitable for large sellers.<\/p>\n\n\n\n \u25cf 2. 9610 Cross-Border E-Commerce Small Package Export Model<\/p>\n\n\n\n Scope of Application: Direct-to-consumer (D2C) cross-border e-commerce.<\/p>\n\n\n\n Policy Incentives:<\/p>\n\n\n\n \u25aa For shipments with a value of \u22645,000 yuan per consignment, customs clearance may be processed via \u201citemized release and aggregated reporting.\u201d<\/p>\n\n\n\n \u25aa Enterprises in cross-border e-commerce comprehensive pilot zones are eligible for tax exemption without invoices or a fixed-rate corporate income tax assessment (taxable income rate: 4%).<\/p>\n\n\n\n Advantages: Short delivery routes, fast delivery times, low costs, and high flexibility.<\/p>\n\n\n\n Disadvantages: Suitable for small, high-frequency orders; not suitable for large-scale exports.<\/p>\n\n\n\n \u25cf 3. The 9810 Overseas Warehouse Export Model<\/p>\n\n\n\n Scope of Application: B2B2C model; suitable for medium- to large-sized sellers looking to establish overseas fulfillment centers.<\/p>\n\n\n\n Features:<\/p>\n\n\n\n \u25aa \u201cShip first, order later\u201d\u2014export to overseas warehouses first, then redistribute from there<\/p>\n\n\n\n \u25aa Improve logistics efficiency and reduce damage rates<\/p>\n\n\n\n Risks:<\/p>\n\n\n\n \u25aa Time lags between exports and foreign exchange receipts make the tax refund process more complicated<\/p>\n\n\n\n \u25aa Companies need to improve the integration of overseas warehouse data with domestic customs clearance and tax refund systems.<\/p>\n\n\n\n \u25cf 4. 0110 General Trade Model (Direct Procurement by a Hong Kong Company + Service Company)<\/p>\n\n\n\n Target Audience: Large sellers and brands expanding into international markets.<\/p>\n\n\n\n Procedure:<\/p>\n\n\n\n \u25aa Exports from a mainland company to a Hong Kong company (general trade customs declaration)<\/p>\n\n\n\n \u25aa A Hong Kong company acts as an overseas entity to handle fund receipts and disbursements and manage store operations<\/p>\n\n\n\n Advantage:<\/p>\n\n\n\n \u25aa Complies with traditional export tax rebate policies and has a clear structure<\/p>\n\n\n\n \u25aa Hong Kong companies offer advantages such as low tax rates, no foreign exchange controls, and convenient fund transfers<\/p>\n\n\n\n \u25aa Helps enhance a company\u2019s internationalization and compliance<\/p>\n\n\n\n 05 Compliance Recommendations for Cross-Border E-Commerce<\/mark><\/strong><\/p>\n\n\n\n \u25aa Coordinate with the finance and tax team in advance: Before the policy takes effect, review supply chain invoices, export tax rebate procedures, and foreign exchange receipt processes to avoid audits caused by data inconsistencies.<\/p>\n\n\n\n \u25aa Flexible export options: Small sellers can choose between the 1039 or 9610 models, while larger sellers should consider the 9810 overseas warehouse or the 0110 Hong Kong structure.<\/p>\n\n\n\n \u25aa Increased budget for compliance costs: Once the policy takes effect, cross-border e-commerce businesses will no longer be able to rely on \u201cgray-area practices,\u201d and companies will need to allocate additional funds for financial and tax compliance, as well as for their overseas corporate structures.<\/p>\n\n\n\n \u25aa Leverage digital tools: Use ERP and cross-border tax and finance SaaS platforms to enable end-to-end reconciliation across the entire process\u2014from orders to payments, invoices, and tax refunds.<\/p>\n\n\n\n 06 Conclusion<\/mark><\/p>\n\n\n\n The issuance of Announcements No. 15 and No. 17 of 2025 marks the cross-border e-commerce industry\u2019s official departure from its \u201cgray-area\u201d existence and its transition to a new phase characterized by transparency, compliance, and internationalization.<\/p>\n\n\n\n For cross-border e-commerce companies, this presents both a challenge and an opportunity. Those that can quickly adapt their business models and strengthen their financial and tax management will stand out in the next round of industry consolidation.<\/p>\n\n\n\n If you are interested in services such as designing cross-border e-commerce compliance models, registering a company in Hong Kong, or optimizing export tax rebates, please feel free to contact our team of professional consultants. We will help you achieve more efficient global operations within a compliant framework.<\/p>\n\n\n\n Previous Recommendations<\/p>\n\n\n\n \u25aa Tax Challenges and Compliance Guidelines for Cross-Border E-Commerce: From Export Tax Rebates to Overseas Taxation<\/p>\n\n\n\n \u25aa Analysis of Announcements No. 15 and No. 17 of 2025: Four Compliance Models and Implementation Procedures<\/p>\n\n\n\n \u25aa What Is Phase IV of the Golden Tax System? The Truth About \u201cData-Driven Taxation\u201d That Cross-Border E-Commerce Sellers Must Know<\/p>\n\n\n\n END<\/p>\n\n\n\n Follow the \u201cQicaiying Cross-Border Compliance Consulting\u201d video channel to see more great content<\/p>\n\n\n\n The articles on this official account are provided for cross-border compliance reference only; please consult a professional advisor for specific tax treatment.<\/p>\n\n\n\n Scan the QR code to add us on WeChat (WeChat ID:jxhcyb<\/mark>) or call our customer service hotline18148556832<\/mark>, Get the \"Compliance Self-Checklist for Sellers Under Announcements No. 15 and No. 17\" and a one-on-one compliance assessment plan for free.<\/p>\n\n\n\n 2025\u5e746-7\u6708\uff0c\u56fd\u5bb6\u7a0e\u52a1\u603b\u5c40\u63a5\u8fde\u53d1\u5e03\u4e86\u4e24\u4efd\u4e0e\u4e92\u8054\u7f51\u5e73\u53f0\u53ca\u51fa\u53e3\u4f01\u4e1a\u7d27\u5bc6\u76f8\u5173\u7684\u91cd\u8981\u6587\u4ef6\uff1a \u25aa \u300a\u56fd\u5bb6\u7a0e\u52a1\u603b\u5c40\u5173 […]<\/p>\n","protected":false},"author":16,"featured_media":11019,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[17,18,13],"tags":[1391,1377,1309,1060,817],"class_list":["post-11025","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-allguide","category-recomguide","category-guide","tag-1391","tag-1377","tag-1309","tag-1060","tag-817"],"yoast_head":"\n<\/figure>\n\n\n\n<\/figure>\n\n\n\n<\/figure>\n\n\n\n<\/figure>\n\n\n\n<\/figure>\n\n\n\n<\/figure>","protected":false},"excerpt":{"rendered":"