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<\/p>\nOn September 1, 2026, sellers in Shenzhen\u2019s three major cross-border e-commerce industrial clusters\u2014Longhua, Bantian, and Longgang\u2014received text messages almost simultaneously from their respective tax authorities. The wording was so blunt that it sent a chill down the spines of operations managers: \u201d \u201dYour company is suspected of underreporting Value-Added Tax on export revenue since 2026. Please complete a self-inspection and rectification within 10 days and submit a written report of the findings to the competent tax authority.\u2019 The text message was uniformly sent by the tax system via the 106 SMS platform; the sender\u2019s location was listed as the Shenzhen Tax Bureau, and the message was stamped with the electronic seal of the competent tax office. This was not a drill, nor was it a preliminary warning\u2014it was the first batch of genuine alerts sent to Shenzhen\u2019s cross-border sellers after the \u201cGolden Tax Phase IV\u201d big data automated comparison model triggered a risk identification. According to preliminary statistics from the Shenzhen Cross-Border E-Commerce Association, on September 1 alone, more than 3,700 cross-border e-commerce enterprises in Shenzhen received similar text messages. Among them, Amazon sellers accounted for 62%, TikTok Shop sellers for 18%, and independent website sellers for 11%, with the remainder being sellers operating on multiple platforms.<\/p>\n
The source of these text messages is the 7\u00d724-hour automated data cross-checking model under the Golden Tax Phase IV initiative. Three sets of data\u2014customs declaration data, platform-reported data (overseas platforms such as Amazon, TikTok Shop, eBay, and Wish are all required by local regulations to report seller transaction information to Chinese tax authorities), and the companies\u201d own self-reported data\u2014are pulled into a single working paper in real time; any discrepancy triggers a risk alert. The issues identified with the sellers in Shenzhen this time are highly concentrated in three areas: First, they mistakenly equated \u201dtax-exempt exports\u201d with \u201dzero declaration\u201d and failed to fill in Column 13, \u201dTax-Exempt Export Sales,\u201d on the \u201dVAT and Supplementary Tax Return (for General Taxpayers)\u201d or the \u201dVAT and Supplementary Tax Return (for Small-Scale Taxpayers)\u201d; Second, the time lag associated with the 9810 overseas warehouse model was not properly addressed, resulting in missing data on overseas warehouse inventory receipts and end-user sales; third, the discrepancy between the amount of cash withdrawals and the full GMV reported by the platform was automatically identified as \u201cundeclared revenue.\u201d The \u201cwindow period\u201d of the past\u2014which relied on manual spot checks followed by a unified year-end tax settlement\u2014no longer exists in the era of the Golden Tax Phase IV system.<\/p>\n
Qicaiying Group specializes in end-to-end financial and tax compliance services for cross-border e-commerce. For Shenzhen-based sellers who receive text messages regarding tax authority self-inspections, we provide comprehensive remediation support\u2014from data comparison, retroactive filing of tax-exempt export sales, and retention of \u201cfour-flow alignment\u201d documentation to the preparation of written self-inspection reports. Qicaiying is a board member of the Shenzhen Cross-Border E-Commerce Association. With eight years of deep involvement in Shenzhen\u2019s cross-border e-commerce ecosystem, the company is well-versed in the audit criteria and document templates used by the competent tax offices in Longhua, Bantian, and Longgang districts. For inquiries, please call 18676749275 or add us on WeChat: Qicaiyingjituan.<\/p>\n
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To understand the nature of this self-inspection, we must first understand what exactly the \u201dGolden Tax Phase IV\u201d initiative is assessing. The Golden Tax Phase IV big data platform has already established data interoperability with the General Administration of Customs, the State Administration of Foreign Exchange, the People\u2019s Bank of China, and the headquarters of various cross-border e-commerce platforms. At the beginning of each month, Customs pushes the previous month\u2019s export customs declaration details, including fields such as export date, commodity HS codes, declared value, transaction method, and shipper\/consignee information; platforms such as Amazon and TikTok Shop, in accordance with their data-sharing agreements with Chinese tax authorities, regularly push data on sellers\u2019 GMV, commissions, refunds, and platform fees; The VAT return forms submitted by enterprises to the tax authorities serve as the \u201cbenchmark\u201d for verification under Phase IV of the Golden Tax Project. Once these three sets of data enter the comparison model, the system automatically calculates discrepancies between customs declaration amounts and reported amounts, between platform-reported GMV and reported revenue, and between foreign exchange receipts and reported sales.<\/p>\n
The risk points identified in Shenzhen this time center on three typical discrepancies. The first is the time lag associated with the 9810 overseas warehouse model: for goods cleared under the 9810 regulatory procedure, entry into the warehouse is deemed an export; however, actual end-user sales are spread out over subsequent months, resulting in the customs declaration value for the current period exceeding the actual sales for that period. For example, a seller declared goods worth 2 million yuan for entry into an FBA overseas warehouse under the 9810 model in September, but actual sales on the Amazon backend that month totaled only 1.3 million yuan, leaving 700,000 yuan worth of goods still in the overseas warehouse inventory. This time lag is compliant in itself, but the company must simultaneously provide overseas warehouse inventory lists, ocean bills of lading, and detailed records of warehouse receipts and shipments during quarterly filings; otherwise, the Golden Tax Phase IV system will identify the 700,000 yuan discrepancy as \u201dundeclared sales.\u201d The second category involves discrepancies between withdrawal proceeds and platform-reported figures: withdrawal tools such as Wanlihui and Payoneer remit net proceeds after deducting costs such as commissions, advertising fees, and warehousing fees, whereas the platform reports data based on the full GMV amount. For example, if a seller receives 1.3 million yuan via Wanlihui, but Amazon reports the full amount of 2.2 million yuan to the Chinese tax authorities, the 900,000 yuan difference must be substantiated with detailed documentation\u2014such as \u201dplatform fees, advertising fees, commissions, and refunds\u201d\u2014to demonstrate the reasonableness of the declaration. The third category involves the closure of loopholes in export invoicing: Following Announcement No. 17 of 2025, export agents must truthfully report the information of the actual principal. The previous practice of using \u201dXYZ Import-Export Company\u201d as a front for exports has been identified by the system.<\/p>\n
The core issue behind the recent naming and shaming of a large number of sellers in Shenzhen is not tax evasion, but a lack of basic knowledge regarding tax filing\u2014specifically, the misconception that \u201dtax-exempt exports\u201d and \u201dzero-rated filings\u201d are one and the same. These two concepts represent entirely different procedures within the VAT filing system. \u201dTax-exempt exports\u201d refer to a tax incentive that exempts eligible exported goods from value-added tax, as stipulated in the \u201dNotice of the Ministry of Finance and the State Taxation Administration on the Full Implementation of the Pilot Program for Replacing Business Tax with Value-Added Tax\u201d (Cai Shui [2016] No. 36) and subsequent VAT exemption policies for exported goods and services. However, \u201dtax exemption\u201d does not mean \u201cno filing.\u201d A \u201czero declaration\u201d refers to a situation where no taxable sales occurred during the reporting period, whereas \u201ctax-exempt exports\u201d involve sales that have taken place but are eligible for tax exemption; the reporting criteria for the two are entirely different.<\/p>\n
Specifically, when it comes to filling out the tax return, the procedures for small-scale taxpayers and general taxpayers differ. Small-scale taxpayers must complete Column 13, \u201dTax-Exempt Export Sales,\u201d on the \u201dValue-Added Tax and Supplementary Taxes Return (for Small-Scale Taxpayers).\u201d This column is a key field used by the Golden Tax Phase IV system to verify the completeness of export transaction declarations. If \u201dTax-Exempt Export Sales\u201d is left blank, the export amounts present in the customs declaration data will be identified as a reporting omission, triggering this warning. General taxpayers, on the other hand, must report tax-exempt revenue separately in the \u201dTax-Exempt Exports\u201d column of the \u201dDetailed Statement of Tax Exemptions and Reductions\u201d in addition to the \u201cVAT and Supplementary Tax Return (for General Taxpayers).\u201d They must also reflect this amount in Column 9, \u201cSales of Tax-Exempt Items,\u201d of \u201cSupplementary Schedule (I) to the VAT Return.\u201d Failure to complete any of these steps will be identified by the Golden Tax Phase IV system as \u201cincomplete reporting of export business.\u201d A cross-border seller of home goods in Longgang, Shenzhen, was recently singled out for this issue, the root cause was that for a cumulative total of 24 million yuan in customs-declared exports in 2025, the company failed to fill out Column 13 and the \u201cTax Exemption and Reduction Detail Statement.\u201d Even though the company had indeed benefited from tax exemption policies, from the perspective of the tax return, this constituted \u201cfailure to report,\u201d which triggered a system alert.<\/p>\n
Agency exports are another common pitfall. Under the agency export model, the principal (the actual seller) must apply to the agent (the foreign trade agency) for an \u201dAgency Export Certificate.\u201d The agent uses this certificate to file for export tax rebates or tax-exempt status; however, more importantly, the agent must proactively remind the principal to handle their own VAT filing independently. In practice, many sellers engaged in agency exports assume that their filing obligations are fulfilled simply by handing over the \u201cCertificate of Agency Export\u201d to the agency, and thus fail to separately list tax-exempt export sales on their own VAT return forms. Following the issuance of Announcement No. 17 of 2025, this loophole was completely closed by the Golden Tax Phase IV initiative\u2014agents are now required to report the information of the actual principal, making it impossible for the principal to \u201cturn a blind eye\u201d any longer.<\/p>\n
To make matters worse, less than 24 hours after the Shenzhen self-inspection text message was sent, Amazon China\u2019s finance team resent the Q4 2025 tax report on the morning of September 2, Some sellers found significant discrepancies between the latest report and the version they received earlier this year\u2014data on deductions such as commissions, platform fees, and advertising fees had been uniformly adjusted upward by the system, resulting in a discrepancy in sellers\u201d actual net profit ranging from 5% to 12% between the two reports. This adjustment stems from Amazon\u2019s recalibration of the reporting criteria under the \u201dMarketplace Facilitator\u201d model, in accordance with reporting agreements with the U.S. Internal Revenue Service and Chinese tax authorities. In short, the GMV data Amazon reports to Chinese tax authorities is now more comprehensive and closer to the full amount, resulting in a significantly higher reported comprehensive expense ratio for sellers compared to the previous version.<\/p>\n
This change has directly amplified the discrepancies identified by the Golden Tax Phase IV comparison. According to the latest report received by an Amazon seller in Shenzhen, the platform reported a total of 18.5 million yuan for Q4 2025, while the company\u2019s actual declared tax-exempt export sales amounted to only 12 million yuan; the resulting discrepancy of 6.5 million yuan was immediately flagged by the system. It is particularly important to note that the discrepancy between the net withdrawal amount and the GMV reported by the platform is currently the most sensitive comparison metric under the Golden Tax Phase IV system\u2014tools such as Wanlihui and Payoneer remit net amounts after deductions, whereas the platform reports the full amount before deductions, resulting in an inherent discrepancy between the two. Sellers must prepare a complete platform settlement breakdown, listing each transaction\u2019s sales, commissions, advertising fees, refunds, platform fees, and withdrawal amounts, and cross-verify these figures using three types of documents: emails from the platform\u2019s backend, settlement reports, and withdrawal slips. If this chain of evidence is missing, the discrepancy will automatically be deemed \u201dundeclared income.\u201d<\/p>\n
Qicaiying Group provides comprehensive data compliance processing services for cross-border e-commerce across all platforms, covering the translation of settlement details from major platforms such as Amazon, TikTok Shop, Temu, SHEIN, Shopee, Lazada, and eBay, as well as reconstruction of commission structures, and reverse verification of withdrawal chains, ensuring a one-to-one reconciliation between platform-reported data and corporate tax filings. Qicaiying is a board member of the Shenzhen Cross-Border E-Commerce Association and is well-versed in the conversion rules between major platforms\u2019 API reporting standards and tax filing requirements. Consultation Hotline: 18676749275; add WeChat: Qicaiyingjituan.<\/p>\n
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The overseas warehouse model is becoming an increasingly mainstream logistics option for cross-border sellers in Shenzhen. In addition to 9610 small-package direct mail, B2C cross-border direct mail, and traditional CIF\/CIP trade, the \u201d9810 cross-border e-commerce export to overseas warehouses\u201d model\u2014which offers controllable logistics costs, the ability to reuse returned goods, and faster delivery times than direct mail\u2014has become an almost unavoidable choice for sellers with annual sales in the tens of millions. However, the biggest compliance challenge with the 9810 model is the time lag between the point of export and the point of revenue recognition. Under the 9810 regulatory framework, goods are considered exported the moment they enter the warehouse; however, for corporate financial purposes, revenue is not recognized until the goods are actually sold to the end consumer at an Amazon FBA warehouse. In the past, many sellers managed to get by by glossing over this time lag, but under the \u201cGolden Tax Phase IV\u201d system\u2019s 24\/7 automated cross-checking, any discrepancy between customs declarations and reported data is now captured in real time.<\/p>\n
To properly address the 9810 time discrepancy, three steps must be taken. First, establish a monthly inventory count sheet for the overseas warehouse, recording details of goods received, shipped, and on hand on a monthly basis, and cross-verify this information against customs declarations, ocean bills of lading, and data from the overseas warehouse\u2019s WMS system. Second, prepare a \u201d9810 Overseas Warehouse Sales and Customs Declaration Discrepancy Reconciliation Statement\u201d on a monthly or quarterly basis (monthly is recommended to ensure a more comprehensive chain of accounting evidence), specifically listing the current period\u2019s customs declaration amount, actual sales amount for the period, ending inventory value, overseas warehouse name, and corresponding platform and store. Third, for the portion where current-period sales are less than the current-period customs declaration amount (i.e., the portion still in overseas warehouse inventory), this must be noted in the supplementary materials of the VAT return under the category \u201cDeemed domestic sales but revenue not yet recognized,\u201d and a comprehensive reconciliation must be completed before the annual tax settlement. In September, a seller in Bantian declared 2 million yuan via the 9810 model but had actual sales of only 1.3 million yuan for the period, resulting in a 700,000-yuan discrepancy flagged by the system. However, because the company provided a complete FBA overseas warehouse inventory count sheet and discrepancy reconciliation statement, it ultimately succeeded in resolving the issue and lifting the risk warning within 10 days.<\/p>\n
Conversely, the 9810 model also has an easily overlooked \u201dred line\u201d that can backfire\u2014when goods are returned from an overseas warehouse to China, a distinction must be made between a return and an FBA transfer between warehouses. Returns involve a negative-value offset declaration, and the calculation basis for the reversal of input tax is the original purchase cost, not the current sales price. If the offset is based on the current sales price, it will be identified as an under-offset of input tax. Internal transfers between FBA warehouses are not considered exports and are treated solely as a change in inventory ownership. These details are precisely the most easily identifiable vulnerabilities in the Golden Tax Phase IV system.<\/p>\n
Prior to the issuance of Announcement No. 17 of 2025, a gray-area practice known as \u201dexport through a third party\u201d had long existed in Shenzhen\u2019s cross-border trade sector\u2014small sellers without import-export operating rights would use the name of an \u201dXX Import-Export Company\u201d with the necessary qualifications to declare and export goods, while their own companies were solely responsible for supplying the goods and had their income tax assessed and collected through the agency company. This model had been virtually an unwritten industry rule for over a decade, but Announcement No. 17 of 2025 strengthened the reporting obligations of agents, causing the \u201cGolden Tax Phase IV\u201d initiative to completely close this loophole.<\/p>\n
According to Announcement No. 17, when applying for a \u201dCertificate of Agency Export,\u201d the agency exporter must truthfully report the actual principal\u2019s Unified Social Credit Code, company name, contact information, details of the actual exported goods, and the corresponding purchase contract number and invoice number. In the principal\u2019s own corporate tax return, the value of goods exported through an agent must be listed separately, and tax-exempt export sales must be reported in the \u201dDetailed Statement of Tax Exemptions and Reductions.\u201d The past practice of \u201cborrowing another party\u2019s name\u201d for exports and then neglecting to file the necessary declarations will no longer be tolerated in the Golden Tax Phase IV era\u2014if the actual exporter shown in customs declaration data is an agency company, but the principal\u2019s own tax return contains no export sales data, the system will automatically flag this as \u201cthe principal concealing export revenue.\u201d<\/p>\n
This change has a structural impact on small and medium-sized sellers in Shenzhen. Many sellers who have long relied on leading companies to expand their exports are suddenly faced with two choices: either immediately establish their own import-export operating rights by completing the filing and registration as a foreign trade operator, customs consignee\/consignor registration, export tax refund (exemption) filing, and foreign exchange receipts and payments list registration; or completely abandon their export business, returning to domestic sales or transitioning to the role of a supplier. The former requires a thorough review of supply chain contracts, payment and collection channels, and the export document archiving system; the latter involves strategic adjustments for the business. Qicaiying Group provides one-stop import-export licensing services for cross-border e-commerce enterprises, covering everything from Foreign Trade Operator Filing to coordinated registration across multiple departments\u2014including customs, foreign exchange, and tax authorities\u2014reducing the average processing time to 15 business days.<\/p>\n
Upon receiving the text message, sellers in Shenzhen must complete a self-inspection within 10 days and submit a written self-inspection report to the competent tax office. The standard rectification process consists of four steps. Step 1: Export all data: Export the current settlement details from the backends of platforms such as Amazon and TikTok Shop; export the current customs declarations from the Customs Electronic Port; and export the current foreign exchange receipts from the bank. Consolidate these three sets of data into a single working paper. Step 2: Break down entries and file supplementary declarations: In the VAT return, break down the declarations by platform. Small-scale taxpayers must complete Line 13, while general taxpayers must simultaneously complete the \u201cExport Tax Exemption\u201d column in the \u201cTax Exemption and Reduction Detail Form\u201d and the \u201cTax-Exempt Items\u201d column in \u201cAppendix (I).\u201d Step 3: Prepare the \u201cFour-Flow Integration\u201d Documentation: Ensure a complete closed-loop of evidence across the four categories: contract flow (purchase contracts + sales contracts), capital flow (bank statements + payment platform transaction records), invoice flow (purchase invoices + sales invoices), and goods flow (customs declarations + logistics documents + overseas warehouse inbound and outbound slips). Step 4: Prepare a self-inspection report: Outline the self-inspection process, issues identified, the amount to be reported retroactively, and follow-up preventive measures. Attach a list of supporting documents, have the report signed and stamped by the legal representative, and submit it to the competent tax office.<\/p>\n
After completing their self-inspections, Shenzhen sellers still face a choice regarding their long-term compliance path\u2014whether to relocate to the Fujian Comprehensive Pilot Zone to take advantage of the preferential assessed-taxation policy. In 2026, the Fujian Comprehensive Pilot Zone will officially implement the \u201dfixed-rate taxation policy for the portion of cross-border e-commerce retail exports subject to VAT without valid purchase documentation,\u201d with a taxable income rate of 4%. When combined with the 5% tax rate for small and micro enterprises, the actual tax burden will be approximately 0.2% of revenue. To qualify for this policy, four mandatory conditions must be met: the enterprise must be registered with the industrial and commercial authorities within the Fujian Comprehensive Pilot Zone; export customs clearance must be processed through the customs office in the Fujian Comprehensive Pilot Zone; the transaction must fall under the category of \u201dno valid purchase documentation\u201d; and the enterprise must already be benefiting from the VAT exemption policy for cross-border e-commerce retail exports. If Shenzhen-based sellers decide to relocate, they will need to reassess their supply chain, warehousing, and talent strategies\u2014it is not simply a matter of \u201cchanging their registered location.\u201d However, the effective tax burden of 0.2% is indeed highly attractive to medium-sized sellers.<\/p>\n
Finally, it must be emphasized that self-inspection and rectification are not one-time actions, but rather a compliance system that requires long-term maintenance. Qicaiying Group provides full-cycle services ranging from the preparation of current self-inspection and rectification reports to quarterly compliance self-checks under the \u201cGolden Tax Phase IV\u201d framework, as well as the archiving of \u201cfour-stream integration\u201d vouchers throughout the year. Having provided financial and tax compliance support to over 18,000 corporate clients, the firm is a council member of the Shenzhen Cross-Border E-Commerce Association and Vice President of the Shenzhen Bookkeeping Agency Industry Association. Our in-house accounting firm holds Hong Kong AFRC certification and a Global Vendor CPA license, with a local service network covering more than 40 countries worldwide. Qicaiying specializes in core areas such as cross-border e-commerce financial and tax compliance, export tax rebates, VAT filing, transition to audit-based taxation, ODI filing, legalization of overseas documents, CRS reporting, and transfer pricing contemporaneous documentation. Consultation Hotline: 18676749275. Add WeChat: Qicaiyingjituan.<\/p>\n
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