On June 22, the Shenzhen Municipal Bureau of Commerce held a policy interpretation briefing for cross-border e-commerce practitioners. This briefing focused on practical compliance issues that are generally concerned by the industry, and clarified official management standards and operational guidelines one by one around core issues such as corporate income tax, value-added tax collection and management standards, 0110 trade model specifications, the implementation of the 9810 export tax rebate auxiliary system, and centralized customs declaration for multiple stores.
Previously on June 3, the Shenzhen Municipal Bureau of Commerce held a special symposium for new media companies and finance and taxation companies in the field of cross-border e-commerce. Two special meetings within one month released a clear signal for industry development: the country’s orientation to support the high-quality development of cross-border e-commerce has remained unchanged, but the era of barbaric growth of the industry has completely ended. The profit-making model relying on poor information, regulatory gaps, and gray operations will completely withdraw from the market. Cross-border e-commerce has officially entered the development stage of sunshine, standardization, and transparency with compliance dividends.
1. Clear corporate income tax collection and administration standards
The regulatory authorities have clearly stated that the store holder is the legal tax payer, and the GMV calculated by the platform will be directly used as the core basis for determining operating income. It will no longer allow blurring the relationship between the store and the operating entity, and will not leave room for the operation of splitting income to avoid taxation through unreasonable structures. The core regulatory requirements include four points: First, audit and collection will be fully implemented in 2026, requiring enterprises to establish a standardized financial accounting system as soon as possible; second, enterprises are allowed to combine the characteristics of cross-border e-commerce operations
Reasonable cost deductions, platform commissions, advertising fees, overseas warehouse fees, domestic procurement costs, employee salaries, etc. can all be calculated and deducted based on actual business conditions; third, it is clear that operating profits must be entered into public accounts, and accounting and tax filing must be done as required. This is an untouchable regulatory red line. At the same time, out of consideration for supporting small and medium-sized sellers, it is not mandatory for each store to have an independent physical office space; fourth, existing compliance issues will be reviewed and dealt with in batches, and companies that have not received verification notices must also complete compliance adjustments as soon as possible.
2. The pay-for-export model is completely suspended
The briefing clearly corrected the misunderstanding that “as long as there are platform orders, exports are compliant and you can enjoy tax rebates and tax exemptions”, it was proposed that online sales data can only prove transaction behavior, but cannot prove the actual export of goods, the compliance of export entities, and the legality of logistics links. Subsequent tax verification will use the “four-flow closed loop” of sales flow, cargo flow, customs declaration flow, and capital flow as the core standard. Only with a complete traceable business evidence chain can you enjoy export-related tax benefits, and data-penetrating supervision will become a normal management method.
The pay-for-export model does not have a real customs declaration entity, matching logistics track and compliance documents. Once verification is triggered, you will face VAT backpayment, late payment fees and even administrative penalties. It has become one of the highest-risk gray operations in the industry.
3. Shell companies with the 0110 reporting model are explicitly prohibited
In response to the recent rumor circulating in the market that “it is the best solution for shell overseas companies to apply for export tax rebates with the 0110 model”, both meetings made clear clarifications: the operation of domestic team operations, collocation of three overseas shell companies with no actual operating capabilities, and the operation of applying for export tax rebates using the 0110 model has no basis for compliance at all, and is a pattern of violations that regulatory authorities focus on cracking down on.
Not only will this model be penetratingly reviewed by the regulatory authorities in accordance with the principle of “substance over form” and directly identified as a controlled foreign enterprise, it will also have major flaws in related-party transactions, which can easily trigger special investigations into the authenticity of trade and customs declarations. Overseas profit retention, capital return, related profit distribution and other aspects will also become the focus of supervision. Blind application of this model will not only fail to obtain tax refunds, but will also face penalties such as tax repayments, fines, and late payment fees.
4. Multiple support policies were implemented simultaneously to release dividends
While delineating regulatory red lines, this presentation also announced a number of benefits to support cross-border e-commerce: First, the Shenzhen 9810 cross-border e-commerce overseas warehouse tax refund channel has been fully unblocked, and the 9810 tax refund auxiliary system being developed locally is expected to be launched within the year, and the system can automatically
Correlating customs declaration data, overseas warehouse inventory data, and store sales data, automatically completes matching write-offs, completely solving the write-off problem faced by sellers in the past where the number of customs declarations is inconsistent with store sales. A small-scale pilot for centralized customs declaration in multiple stores has also been launched, and will be gradually optimized and promoted in the future.
In addition, a number of inclusive support policies are being promoted: a ticketless tax-free service platform for the 9610 model is being built, covering TikTok
On mainstream platforms such as Shop, Shopee, Shein, and AliExpress, sellers can be exempted from VAT liability as long as they complete the claim on the list; compliant freight forwarders will receive special support from the government, and sellers that achieve full-link sunny operations can enjoy logistics fee reductions; the government will issue payments to leading overseas warehouses
Special subsidies require them to reduce or reduce warehouse rent and delivery fees to compliant sellers; support for the 9710 model will also be further increased, and real transactions through channels such as Alibaba International Station and independent stations can enjoy a higher upper limit of foreign exchange settlement subsidies. At the same time, regulatory authorities will also crack down on false transactions and violations of subsidy fraud.
Industry insiders said that the release of this series of policies means that the development logic of the cross-border e-commerce industry has shifted from “fighting for speed and making quick money” to “fighting for compliance and long-term operation.” If enterprises build a complete compliance management system as soon as possible, they can fully enjoy the dividends of various policies and achieve stable and healthy overseas development.
