In 2026, the data interconnection mechanism of the three departments of customs, foreign exchange, and taxation has been fully implemented. The fourth phase of the Golden Tax has completed the automatic comparison and upgrade of invoices, customs declarations, funds, and logistics data across the entire link. Many declaration details that were easily overlooked in the past have now become “invisible thresholds” that have stuck in the tax refund process.
Many cross-border e-commerce companies’ businesses are fully compliant, but due to unfamiliarity with the new review rules, tax refunds have been delayed in their accounts, and they even face risks of input transfers and tax recovery.
Many companies only attribute the problem to financial reporting errors, but ignore that the audit rules under the New Deal have been comprehensively tightened: input audit, document matching, foreign exchange collection deadline, source of goods, and filing information. If there is a flaw in any link, the entire batch of tax refunds will be suspended.
Currently, there are six high-frequency stuck points for export tax refunds. Enterprises can check and rectify them accordingly:
Stuck point 1: Input VAT invoice audit comparison failed This is the number one problem in tax refund rejections in 2026. After submission for pre-review, it directly shows that the purchase voucher is missing, there is no electronic information, and the invoice status is abnormal.
It is mainly caused by two types of reasons: First, the financial operation error is to mistakenly select “Tax Refund Check” instead of “Deduction Check”, the invoice data enters the deduction database, and the tax refund module cannot capture the information; second, the upstream supplier invalidates the invoice, or the invoice is listed as a fugitive, and the invoice is marked as an abnormal voucher.
According to the new regulations on the management of export tax refund invoices, tax refund declarations will not be accepted for invoices that have not obtained audit passing information. If you select the wrong check category, you need to submit a voucher return application, which can take as short as three to five working days or as long as half a month before the data can be released.
In practice, it is recommended that enterprises wait 2-3 working days to complete the audit after receiving the input invoice, confirm that the status is normal before entering it into the system, and at the same time verify the tax credit of upstream suppliers in advance to avoid the invoice being invalidated midway.
Stuck point 2: Information on the customs declaration form is inconsistent with the input invoice. Even if the product name is abbreviated, specifications and models are omitted, measurement units are not unified, or there is a deviation in the HS code, the system will determine that the goods flow is inconsistent and will be directly rejected.
According to the management requirements for export tax rebate documents, the cargo information of invoices, customs declarations, and purchase contracts must be highly consistent. In 2026, the system will add an automatic comparison function of HS codes. Inconsistent codes will directly trigger a three-level risk warning.
In practice, it is recommended to wait until the draft customs declaration is issued before issuing input invoices. Strictly ensure that the text of the invoice and the invoice are completely unified. For businesses that require conversion of measurement units, conversion instructions should be prepared in advance and kept for archiving.
Stuck point three: Domestic source of supply information does not match. The supply area and county filled in the customs declaration form is inconsistent with the registration place of the input invoice issuance company. Especially if the local source of supply is reported for cross-provincial procurement, it will be directly marked as a document doubt and entered into a long-term correspondence process. Enterprises exporting from multiple suppliers are most likely to have this kind of problem.
At present, customs declaration data will be pushed to the tax system simultaneously, and the information filled in by the invoicing company’s location and source of goods will be automatically compared. If the frequency of conflicts is too high, upstream and downstream coordinated investigations will be initiated.
In practice, it is recommended that one order corresponds to one supplier, and the customs declaration items are filled in separately. For goods purchased from other provinces, the source of goods from other provinces should be filled in truthfully. Do not fill in the local territory uniformly to save trouble.
Card point 4: Overdue foreign exchange collection If the goods have been declared for export and have not completed the public foreign exchange collection after the VAT declaration deadline in April of the following year, the corresponding batch of business will not be able to handle tax refunds and can only be converted to tax-free processing, and the input tax must be transferred out. Enterprises with the 9810 overseas warehouse model are most likely to have overdue problems because they prepare goods first and then collect payment at retail.
In accordance with the management requirements of “who exports, he collects foreign exchange”, except for a few force majeure circumstances, export business that does not collect foreign exchange within the specified period cannot enjoy the tax refund policy. The foreign exchange flow in 2026 has been included in the mandatory tax refund review data. Private customers collect payment for goods and long-term failure to collect payment from the public will directly block the review progress.
It is recommended that enterprises reasonably control the pace of order repayment, and adjust the declaration method in advance for businesses that have not settled foreign exchange near the deadline to avoid temporary tax deductions and transfer out inputs.
Point 5: The filing documents are incomplete. When the tax initiates a letter investigation and verification, the company cannot produce the complete purchase contract, domestic logistics documents, warehousing orders, and overseas logistics vouchers. Only invoices and customs declaration forms will cause the chain of evidence to be broken and the review process to be put on hold indefinitely.
According to the requirements, the retention period of the complete set of registration documents of export enterprises is not less than ten years. In 2026, verification will tend to be penetrating management. The lack of logistics and warehousing certificates will be directly identified as business doubts. Once exports with fraudulent orders and no-goods declarations are verified, not only will tax refunds not be granted, but also tax refunds obtained by fraud will be dealt with strictly.
It is recommended that enterprises establish a monthly filing system for documents, supporting contracts, logistics orders, and warehousing and outgoing records for each batch of export orders to form a closed-loop data response verification.
Stuck point 6: Enterprise registration information is not consistent with actual operations. The business address, account bank, trade mode and actual business in the export tax refund and tax exemption registration are inconsistent, or the trade mode registration type is wrongly selected, and documents are mixed by multiple entities. This will lead to logical conflicts in the declaration data and will be continuously intercepted by the system. Enterprises with confusing accounting documents and random mixing of documents will be marked as high-risk categories. Each tax refund must be manually reviewed item by item, and the review cycle will be doubled.
It is recommended that enterprises distinguish between the different filing types of 9610 tax exemption, 9810 tax exemption and general trade tax refund, and strictly separate the documents for different business entities to prevent cross-use.
In response to the problem of stuck tax refunds, companies can establish normalized management plans to avoid risks in advance: first, implement a pre-examination system, complete pre-inspection of documents before formally submitting declarations, and correct product names, source of goods, and invoice audit issues in advance. Frequent withdrawal and re-reporting will increase the risk level of the company; second, check input invoices in batches, do not check thousands of special invoices in large batches at one time, and prevent tax data
According to congestion, invoices have been stranded for a long time without information; third, different trade models are separately accounted for, and small package retail exports and general trade tax refund business are separated into main operations, and the tax-free business and tax refund business have independent accounts to avoid mutual involvement and trigger early warnings; fourth, strict control of upstream invoicing quality, agree on invoicing specifications in advance, prevent suppliers from blanket invoicing and temporary invalidation of bills, and reduce the chain impact caused by abnormal vouchers.
The tax refund review in 2026 has entered the era of full data comparison. Tax refund stuck is no longer just a simple declaration operation problem. Any loophole in the process will cause long-term occupation of corporate funds.
If the company’s internal finance and taxation team is not familiar with the new rules, it can also connect with formal finance and taxation agencies that are deeply involved in cross-border tax refund business, investigate risks in advance based on its own trade model, resolve various doubts in the pre-review stage, and ensure that tax refunds are received on time and smoothly.
