{"id":11028,"date":"2026-06-10T16:55:24","date_gmt":"2026-06-10T08:55:24","guid":{"rendered":"https:\/\/www.qicaiying.cn\/?p=11028"},"modified":"2026-06-10T16:55:25","modified_gmt":"2026-06-10T08:55:25","slug":"2026%e5%b9%b415%e5%8f%b7%e4%b8%8e17%e5%8f%b7%e5%85%ac%e5%91%8a%e8%a7%a3%e8%af%bb-%e8%b7%a8%e5%a2%83%e7%94%b5%e5%95%86%e5%9b%9b%e7%a7%8d%e5%90%88%e8%a7%84%e6%a8%a1%e5%bc%8f%e5%8f%8a%e8%90%bd%e5%9c%b0","status":"publish","type":"post","link":"https:\/\/www.qicaiying.cn\/en\/archives\/11028","title":{"rendered":"Analysis of Announcements No. 15 and No. 17 of 2026 | Four Compliance Models for Cross-Border E-Commerce and a Practical Implementation Guide"},"content":{"rendered":"
In 2026, the State Taxation Administration issued Announcements No. 15 and No. 17, setting forth new requirements for the financial and tax management of cross-border e-commerce.<\/p>\n\n\n\n
Announcement No. 15 stipulates that online platforms must report sellers\u2019 identity information and revenue data to the tax authorities. This requirement applies to both domestic platforms (such as Taobao, JD.com, Pinduoduo, and Douyin) and international platforms (such as Amazon, eBay, AliExpress, and Temu), provided that these platforms provide services within China.<\/p>\n\n\n\n
Announcement No. 17 requires export agencies to disclose information about the actual parties commissioning the exports. These two provisions form a complete data chain, enabling tax authorities to cross-verify the authenticity of the data reported by enterprises.<\/p>\n\n\n\n
01 Compliance Risks Faced by Companies<\/mark><\/strong><\/p>\n\n\n\n
Non-compliance with financial and tax regulations can lead to the following risks:<\/p>\n\n\n\n
\u25aa Tax penalties: You will be required to pay back taxes, late payment penalties, and substantial fines.<\/p>\n\n\n\n
\u25aa Criminal Liability: In serious cases, criminal liability may apply.<\/p>\n\n\n\n
\u25aa Damage to corporate reputation: Impact on consumer and partner trust<\/p>\n\n\n\n
\u25aa Financing Challenges: Difficulty in securing investment or going public<\/p>\n\n\n\n
Frequently asked questions include:<\/p>\n\n\n\n
\u25aa Concealing income by receiving payments through personal accounts<\/p>\n\n\n\n
02 Four Compliance Models and Operational Approaches<\/mark><\/strong><\/p>\n\n\n\n
The following four models are applicable to most cross-border businesses. Companies can choose the model that best suits their specific invoice circumstances, or combine multiple models as needed.<\/p>\n\n\n\n
1. Export Tax Rebate Model (Special VAT Invoices)<\/p>\n\n\n\n
2. Tax-Exempt Export Model (Standard Invoice \/ No Invoice in Comprehensive Pilot Zones)<\/p>\n\n\n\n
3. 1039 Market Procurement Model (Individual Business Owners Without Invoices)<\/p>\n\n\n\n
4. Hong Kong Company Procurement + Service Provider Model (Compliant Without Invoices)<\/p>\n\n\n\n
\u25cf Export Tax Rebate Model (Special VAT Invoices)<\/p>\n\n\n\n
Applicable Scenarios: Enterprises eligible to obtain special VAT invoices, such as manufacturing companies and legitimate foreign trade companies, whose business primarily involves general trade or compliant cross-border B2B e-commerce.<\/p>\n\n\n\n
How to Use:<\/p>\n\n\n\n
\u25aa When making a purchase, require the supplier to issue a special VAT invoice that matches the goods declared for customs clearance (with identical names and quantities)<\/p>\n\n\n\n
\u25aa Declare using codes 0110 (general trade), 9710 (B2B direct exports), and 9810 (exports via overseas warehouses)<\/p>\n\n\n\n
\u25aa Collect customs declarations, foreign exchange receipts, and special VAT invoices, and file a return under the \u201cExemption, Offset, and Refund\u201d (for manufacturing enterprises) or \u201cExemption and Refund\u201d (for foreign trade enterprises) schemes.<\/p>\n\n\n\n
Advantage:<\/p>\n\n\n\n
\u25aa Profits can be boosted through tax rebates (e.g., an 8-point invoicing cost corresponds to a 13-point tax rebate, resulting in a net profit of 5 points)<\/p>\n\n\n\n
Note: Invoice compliance requirements are extremely strict.<\/p>\n\n\n\n
\u25cf Tax-Exempt Export Model (Standard Invoice \/ No Invoice in Comprehensive Pilot Zones)<\/p>\n\n\n\n
Application:<\/p>\n\n\n\n
\u25aa Suppliers can only provide standard invoices<\/p>\n\n\n\n
\u25aa Companies registered in cross-border e-commerce pilot zones to engage in 9610 (retail exports) and 9810 (exports via overseas warehouses) (difficult to establish a presence in Shenzhen)<\/p>\n\n\n\n
How to Use:<\/p>\n\n\n\n
\u25aa Standard Invoice Scenario: Based on the filing of a standard invoice, VAT is exempted at the export stage (input tax cannot be offset).<\/p>\n\n\n\n
\u25aa 9610 \/ 9710 \/ 9810 \/ 0110 \/ 1210 (bonded e-commerce) are all acceptable<\/p>\n\n\n\n<\/figure>\n\n\n\n
Features:<\/p>\n\n\n\n
\u25aa Logistics costs are higher than those for general trade, squeezing profit margins<\/p>\n\n\n\n
\u25cf 1039 Market Procurement Model<\/p>\n\n\n\n
Applicable scenarios: Small shipments, mixed cargo, and goods without invoices. In pilot cities, customs clearance is processed through individual business operators, with the value of each shipment not exceeding $150,000.<\/p>\n\n\n\n
How to Use:<\/p>\n\n\n\n
\u25aa Register as a sole proprietor in a pilot area and complete market procurement filing<\/p>\n\n\n\n
\u25aa Use Form 1039 for customs declaration; purchases without invoices are exempt from tax<\/p>\n\n\n\n
\u25aa Corporate income tax is assessed on a fixed-rate basis<\/p>\n\n\n\n
Features:<\/p>\n\n\n\n
\u25aa No invoices are required for tax-free status, and the overall tax burden is low (taxes on 1 million in exports amount to approximately 5,000\u201315,000 yuan)<\/p>\n\n\n\n
\u25aa It is extremely difficult to set up operations in Shenzhen due to geographical and cargo value restrictions.<\/p>\n\n\n\n
\u25aa Must operate on-site in the pilot locations<\/p>\n\n\n\n
\u25cf Hong Kong Company Procurement + Service Provider Model (Compliant Without Invoices)<\/p>\n\n\n\n
Applicable Scenarios: Medium- to large-sized enterprises (with annual export revenue of 20 million or more) that make purchases without invoices and need to mitigate domestic tax pressures while ensuring the compliant repatriation of foreign exchange.<\/p>\n\n\n\n
How to Use:<\/p>\n\n\n\n
\u25aa A Hong Kong company purchases directly from a supplier in mainland China that does not issue invoices and pays for the goods<\/p>\n\n\n\n
\u25aa Hong Kong companies may apply for an \u201coffshore exemption\u201d (if suppliers or customers are not Hong Kong entities and business activities do not take place in Hong Kong, they may be exempt from the 16.51% TP3T profits tax)<\/p>\n\n\n\n
\u25aa Establish a service company in mainland China to provide cross-border services\u2014such as supply chain management and technical support\u2014to Hong Kong companies, and legally repatriate foreign exchange to mainland China based on the \u201cTax Exemption Filing for Cross-Border Taxable Transactions.\u201d<\/p>\n\n\n\n
Features:<\/p>\n\n\n\n
\u25aa Dual tax optimization (tax-exempt status in Hong Kong + tax-exempt status for domestic services), compliant repatriation of funds<\/p>\n\n\n\n
\u25aa A dual-entity structure linking Hong Kong and the mainland must be established<\/p>\n\n\n\n
\u25aa For Hong Kong offshore exemptions, complete business documentation (contracts, shipping documents) must be retained, and service pricing must be reasonable.<\/p>\n\n\n\n<\/figure>\n\n\n\n
1. Map out the business model<\/strong><\/p>\n\n\n\n
First, you need to clarify the company\u2019s business model and select the appropriate compliance path based on the input invoices:<\/p>\n\n\n\n
\u25aa Eligible for special invoices: Calculate the cost including the invoice surcharge and select the export tax refund model<\/p>\n\n\n\n
\u25aa If you can only obtain a standard invoice or no invoice: Select the export duty-free option or the Form 1039\/Hong Kong company model<\/p>\n\n\n\n
2. Establish a Compliance Framework<\/strong><\/p>\n\n\n\n
A well-designed structure can make transaction flows clearer, facilitating the export of goods and the collection of payments. Care must be taken to avoid issues related to affiliations between the parent company and the Hong Kong company, as well as between the retail company and the Hong Kong company.<\/p>\n\n\n\n
3. Practical Implementation of Compliance<\/strong><\/p>\n\n\n\n
This includes preparing import and export qualifications, selecting customs clearance methods, filing for export tax refunds (or exemptions), receiving foreign exchange, accounting, and filing tax returns.<\/p>\n\n\n\n
Key Points:<\/p>\n\n\n\n
\u25aa Export Tax Rebate: You must prepare all necessary documents, such as customs declaration forms, delivery orders, and shipping documents.<\/p>\n\n\n\n
\u25aa Foreign Exchange Receipts: Ensure that the foreign exchange receipt route matches the goods export route<\/p>\n\n\n\n
\u25aa Accounting Treatment: Accurately record sales revenue, as well as logistics costs for the first and last legs of the shipment<\/p>\n\n\n\n<\/figure>\n\n\n\n
04 Cross-Regulatory Profit: A One-Stop Compliance Solution<\/mark><\/strong><\/p>\n\n\n\n
Amid the global wave of cross-border e-commerce, compliance is the cornerstone of steady growth. With years of deep expertise in the field of cross-border compliance, KuaiGuiYing leverages its extensive industry experience and professional team to provide sellers with customized, end-to-end, one-stop compliance solutions:<\/p>\n\n\n\n
\u25aa Global VAT Compliance: We provide efficient, end-to-end services\u2014from tax ID registration and filing to management and deregistration; we promptly handle tax correspondence, assist with EORI applications and inquiries, and accurately manage tax risks.<\/p>\n\n\n\n
\u25aa European EPR\/Product Compliance: We specialize in handling European EPR registration and reporting, and provide authorized representative services in Europe, the UK, and the U.S.; we assist with EU energy efficiency labeling and climate-friendly certification, helping sellers easily adapt to European market regulations.<\/p>\n\n\n\n
\u25aa Overseas Business and Tax Compliance: We offer full-cycle services covering overseas company registration, investment filing, annual audits, and more; we also provide professional support for offshore account applications, as well as changes to company equity and directors.<\/p>\n\n\n\n
\u25aa Global Intellectual Property Compliance: We provide global trademark, patent, and copyright registration services, as well as trademark reexamination services, to comprehensively protect your brand assets and give you peace of mind as you expand into international markets.<\/p>\n\n\n\n
Previous Recommendations<\/p>\n\n\n\n
\u25aa New E-commerce Tax Regulations Take Effect in 2026: China\u2019s Cross-Border Sellers Shift from a \u201cCash Flow-Oriented\u201d to an \u201cOrder-Oriented\u201d Approach\u201d<\/p>\n\n\n\n
\u25aa Implementation of Documents No. 15 and No. 17: Financial and Tax Compliance for Cross-Border E-Commerce Shifts from \u201cOptional\u201d to \u201cMandatory\u201d<\/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 a free copy of the \u201cSelf-Checklist for Four Cross-Border E-Commerce Compliance Models\u201d and a one-on-one compliance assessment plan.<\/p>\n\n\n\n<\/figure>","protected":false},"excerpt":{"rendered":"
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