As mid-2026 approaches, for Chinese cross-border e-commerce sellers, this half-year may be more challenging than ever before. The past model relying on information asymmetry and gray operations is unsustainable, and a new stage centered on data regulation and full-link compliance has begun. For all sellers mining gold in overseas markets, understanding and embracing compliance has become an essential question of survival.

1. The Logic Behind Data Regulation: Why Cross-Border E-Commerce Becomes the "Target Heart"?

Why does tax regulation keep a close eye on cross-border e-commerce? The core lies in the huge gap between official statistics and the real scale.

Official data shows that last year's total cross-border e-commerce export volume was about 2.2 trillion yuan, but the estimated volume of Chinese sellers on Amazon alone reached 7.6 to 8.6 trillion yuan. This trillions-yuan tax loss space naturally becomes a priority in the country's "tax governance through data" strategy.

The state is connecting 28 systems including tax, customs, and foreign exchange through the "Golden Tax Phase IV" and promoting the "Strengthening Foundation Project" from 2025 to 2027 to solidify the tax base. The regulatory logic has shifted from relying on corporate self-declaration to automatic data comparison. At the same time, the state's promotion of global taxation and the State Council's Order No. 837 strengthening overseas investment regulation both declare that the risk of using Hong Kong shell companies for false transactions, the "Savvy Model," has increased sharply. Not only does it face tax and fines, but it may also touch the red line of tax fraud.

2. Four Major Changes in 2026: Termination of Assessment, Return of Subjects

In 2026, sellers must soberly recognize the following four fundamental changes, which are the cornerstones of all compliance path designs.

First, abolish assessed collection and fully implement audit-based collection. The assessed collection of corporate income tax once opened to cross-border e-commerce in some regions has been canceled from 2026. Especially for sellers with overseas warehouse models, audit-based collection will be fully implemented, and taxes must be paid based on real accounts and profits.

Second, store companies must be independent tax subjects. Each store's corresponding company is regarded as an independent "resident enterprise" and must make independent tax declarations separately. Any claim that multiple store incomes can be "consolidated" into one tax declaration is misleading.

Third, the "fake 0110" and "no substantial operation Hong Kong company" models are blocked. The traditional export model of using a Hong Kong shell company as an intermediary is clearly identified as non-compliant by regulators because the "four flows" of commerce, logistics, capital, and information are inconsistent. It not only faces tax and fines but may also involve criminal risks of defrauding export tax rebates.

Fourth, overseas warehouse sellers are mandatorily matched with the 9810 regulatory code. Customs regulatory codes must precisely match business models. The only compliant export channel for overseas warehouse models is 9810, not the 0110 used for general trade. Using 0110 for customs clearance of overseas warehouse shipments is a typical "code mismatch" and will trigger serious tax consequences.

3. 9810: The Optimal Compliance Solution for Overseas Warehouse Sellers

For the vast majority of sellers using Amazon FBA or third-party overseas warehouses, 9810 is the only compliant and cost-optimal choice under the current policy environment.

The 9810 model allows sellers to export goods to overseas warehouses through 9810 regulatory methods first, and then perform tax accounting based on sales proceeds after real sales are generated on the platform.

Its core advantages are: Compliance closed-loop - the entire operation link has laws to follow, and the capital flow, goods flow, and document flow are completely matched; lowest cost - VAT exemption or refund, and corporate income tax is only paid on real profits. Compared with the hidden costs such as domestic sales tax supplementation and Hong Kong company maintenance fees caused by non-compliant operations, the tax burden cost of 9810 is extremely low.

Take a seller with an annual sales volume of 5 million yuan as an example: through 9810 compliant export, VAT can enjoy tax exemption or refund policies, and only corporate income tax needs to be paid on the profit part; based on a profit of 500,000 yuan, the income tax is only 25,000 yuan, and about 130,000 yuan of export tax rebate can be obtained for 1 million yuan of procurement costs. The final comprehensive cost is much lower than the old model. However, through the fake 0110 model, one may face the dilemma of inflated profits, paying several times the tax, and hundreds of thousands of yuan in Hong Kong company maintenance fees.

4. Practical Implementation: Strategies for Single and Multiple Stores

The compliance process of 9810 involves multiple links such as qualification filing, customs declaration, tax refund verification, and bookkeeping and tax declaration, which are professional and cumbersome.

Single store model is relatively standard: After completing customs, tax, and foreign exchange filings, customs declaration through 9810 can choose "tax refund upon departure" or "tax refund after sales completion." Small-scale enterprises can be tax-exempt, and general taxpayers can apply for tax refunds with special invoices. The key is the year-end settlement to ensure that the customs declaration form, sales order, and foreign exchange record correspond one by one.

Multiple store model faces greater challenges: For sellers with dozens of stores, the policy allows "centralized declaration" (i.e., using one main company for unified customs declaration), but customs declaration is only the first step. The core difficulty lies in reasonably allocating the total cost according to the sales proportion of each store and completing the independent declaration and accounting of each store company. Currently, the consolidation of multiple stores within the same competent tax bureau can be implemented, and the implementation rules for cross-tax bureau entities are still being promoted.

In 2026, compliance is no longer a restraint but an entry ticket for a new track. The current global compliance trend is very clear, from the domestic tax strengthening project to new overseas consumer regulation rules. The earlier sellers complete the 9810 compliance layout, the more they can avoid the fermentation of historical legacy issues and maintain long-term operating results!

(Source: Hugo Cross-Border Editorial Department)

Seller's Home Review

The blockage of assessed collection and "fake 0110" marks the end of the era of extensive tax operations. It is recommended that sellers immediately check the "four streams consistency," switch overseas warehouse business to the 9810 model, and ensure that store companies pay taxes independently. The compliance structure has become the core survival threshold of 2026.

Source: Hugo Cross-Border
Original Link: https://www.cifnews.com/article/187118