Core conclusions:Whether cross-border e-commerce exports can receive tax refunds depends not on the platform, but rather on the customs clearance method used. For exports involving retail sales where valid purchase receipts are available, tax refunds can be processed using the “list-based verification and consolidated declaration” method. For those without valid purchase receipts, tax-free treatment is possible in designated pilot areas (where VAT and consumption taxes are exempted). In this case, corporate income tax is calculated based on a rate of 4%. For direct B2B exports, tax refunds can be obtained by submitting VAT invoices. Assuming a refund rate of 13%, an export worth 1 million yuan would result in a refund of approximately 115,000 yuan. For exports through overseas warehouses, tax refunds are granted immediately upon departure, with subsequent calculations for sales proceeds. For first- and second-class export enterprises with high credit ratings, the normal processing time for tax refunds is reduced to within three working days.
1. First, it’s necessary to distinguish between the three different customs declaration methods. The rules for tax refund vary significantly among these methods.
There are three common customs inspection methods for cross-border e-commerce exports. 9610 refers to retail exports, suitable for sellers who prefer direct shipment of small packages, have low unit value per order, and handle many different SKUs. 9710 is B2B direct exports, suitable for cases where orders involve large amounts of goods and stable supply chains. These scenarios are ideal for sellers on Alibaba’s international platforms or those dealing with B-side customers offline. 9810 involves exporting goods via overseas warehouses. Sellers can first prepare goods in bulk at overseas warehouses, and then deliver them directly to end-users based on individual orders. This method is suitable for large sellers on Amazon or independent websites.
The tax treatments for the three modes are different. For the 9610 mode, the key factor is whether there are purchase invoices: if there are invoices, tax refunds can be processed; if not, taxes can be exempted through the comprehensive testing area. The 9710 mode follows the normal trade practices, with tax refunds processed based on VAT invoices. The 9810 mode is unique in that tax refunds can be claimed immediately after goods leave the country, without waiting for the goods to be actually sold.
| Declaration mode | applicable scenarios | Fiscal and tax matters |
|---|---|---|
| 9610 Retail Exports | Small packages can be shipped directly via courier services. Multiple SKUs are supported, and the value of individual shipments is relatively low. | Those with tickets can claim tax refunds; those without tickets are exempt from value-added tax and consumption tax in the comprehensive testing zones. |
| 9710 B2B Direct Exports | Mass sending of orders to foreign companies and B-side clients | Obtaining VAT invoices for general trade exports allows for tax refunds. |
| 9810 products are exported to overseas warehouses. | First, stock the products in overseas warehouses, and then distribute them to the market. | Tax refunds are processed immediately upon departure. The final calculation of taxes is done after the sale has taken place. |
II. How to calculate tax refunds for those who have tickets: A straightforward example for calculation
Take a case where a foreign trade enterprise exports a batch of goods. The ex-factory price of these goods is 1 million yuan. The applicable export tax rebate rate is 13%. The special VAT invoice obtained for purchasing this batch of goods indicates an amount of 885,000 yuan, with a tax amount of 115,000 yuan. The foreign trade enterprise benefits from the tax exemption policy. The amount of tax refund can be calculated based on the taxable amount stated in the special VAT invoice and the tax rebate rate, resulting in a refund of 115,000 yuan. The following conditions must be met: the enterprise must be a general VAT taxpayer and have completed the export tax exemption registration process; the goods must have a customs declaration form for export, and the information on the declaration form must be consistent with the actual situation; the enterprise must receive payment for the goods by the end of the tax exemption application period; and the content of the special VAT invoice must match the information on the customs declaration form.
Manufacturing enterprises follow a different approach: exemption, credit, and refund. The amount of tax refund is calculated by multiplying the export price at FOB value by the exchange rate of the RMB, then subtracting the amount offset by the tax refund rate. The offset amount is determined by multiplying the cost of raw materials purchased during the period by the tax refund rate for exported goods. The amount of tax refund for manufacturing enterprises depends on the amount of tax credits available during that period. Unlike foreign trade enterprises, where the tax refund amount is equal to the input tax amount, this is why the amounts received by both types of enterprises with the same value of goods can differ.
III. How to use the exemption policy without a ticket: Three conditions are required, plus a verification rate of 4%
Exemption from VAT and consumption tax applies to cross-border e-commerce retail enterprises within the comprehensive testing zones. These enterprises can be exempted from these taxes when they export goods without having valid purchase documents. To qualify for this exemption, several conditions must be met: first, the enterprise must be registered within the comprehensive testing zone, and its export details—including the date of export, product name, unit of measurement, quantity, unit price, and total amount—must be recorded on the online e-commerce platform located in the jurisdiction of the comprehensive testing zone. Second, the exported goods must go through the e-commerce export declaration process at the customs office in the jurisdiction of the comprehensive testing zone. Third, the exported goods must not be those explicitly exempted from export tax benefits by the state.
The corresponding method is the fixed-rate taxation of corporate income tax. For cross-border e-commerce retail enterprises in comprehensive pilot zones that meet the requirements, corporate income tax is calculated based on a specified rate of 4%. For example, if an enterprise has annual export revenue of 10 million yuan, its taxable income would be 10 million yuan multiplied by 4%, which equals 400,000 yuan. If the enterprise meets the criteria for small-profit enterprises, additional deductions can reduce the actual amount of corporate income tax payable to around 20,000 yuan. It should be noted that tax exemptions only apply to value-added tax and consumption tax related to exports. Corporate income tax still needs to be declared according to the law. Applications for fixed-rate taxation must be made to the relevant tax authorities.
There is one important restriction regarding the exemption from taxes without a ticket: the information registered on the online platform must be completely consistent with the customs declarations. Any discrepancies will affect your eligibility for tax exemption. In other words, having a ticket does not mean having all the necessary documents; the information registered on the platform serves as your proof.
IV. Overseas Warehouse Model: Tax refunds are available once goods are exported, but it’s necessary to maintain an accurate inventory record.
In the past, one of the problems with overseas warehouses for cross-border e-commerce was the delay in sales realization and the long process involved in tax refund procedures. According to the announcements supporting the development of overseas warehouses for cross-border e-commerce, taxes are refunded immediately upon leaving the country, and sales are recalculated afterward. Goods can be declared for tax refund or exemption as soon as they leave the country, without the need to wait until they are actually sold. This directly helps to reduce the financial burden associated with stock preparation.
The necessary steps include establishing a detailed ledger for tracking inventory in the overseas warehouse. It’s important to keep complete records of storage, logistics, and sales transactions, as well as ensuring that inventory levels are accurately matched with actual sales figures. After each sale, it’s necessary to calculate any discrepancies between the actual sales amount and the recorded inventory levels. If this process isn’t carried out properly, there will be insufficient supporting documentation during tax audits in the future.
Another often overlooked option is the 1039 market procurement trade method. In cases where it’s indeed impossible to obtain import invoices under the 9710 or general trade models, the 1039 export method can be used. This approach allows for exemption from VAT payments, thereby solving the problem of compliant exports without invoices. However, this comes with the cost of giving up the opportunity for tax refunds.
5. Common questions
1. If there are no invoices with input amounts, does that mean that taxes cannot be refunded at all?
It’s not possible to get a refund, but goods without valid purchase receipts cannot be subject to tax exemption. This is determined by the logic of taxation. However, cross-border e-commerce retail enterprises registered in the comprehensive pilot zones and meeting three criteria can benefit from tax exemption for goods without purchase receipts. They are exempt from value-added tax and consumption tax on the export stage, and can also apply for fixed-rate corporate income tax collection. So, the correct question isn’t “how to get a refund without purchasing goods,” but rather “how to include such transactions in the tax-exempt category, while simultaneously controlling corporate income tax liabilities.”
2. Is there any time limit for submitting tax refund applications?
There is a time limit, and it’s also necessary to process the payment for the exported goods at the same time. The declaration for export tax exemption must be completed by the end of the specified deadline. Additionally, the exported goods must receive payment within the specified period. In practice, there are three common reasons for rejection: failure to match the electronic information on the customs declaration form, discrepancies between the invoice details and the customs declaration form, or failure to submit the declaration within the required time frame. A prudent approach is to keep track of each document separately, with corresponding entries in a ledger. Regular checks should be conducted every month to identify any mismatches.
3. How long does it take for tax refunds to be credited to my account after submitting the application?
This relates to the classification of enterprises under export tax rebate management. For first- and second-class export enterprises with high credit ratings, the normal processing time for tax rebates is reduced to within three working days. For enterprises with lower ratings or those making their applications for the first time, the tax authorities will conduct more thorough inspections, resulting in longer processing times. Enterprises can take proactive steps by digitizing their documentation and preparing all necessary materials in advance, thereby reducing the time spent on submitting additional documents.
For factories that engage in cross-border e-commerce, the key step in handling tax returns is to determine the appropriate customs clearance method first. Once the method is chosen, it’s necessary to ensure that all relevant documents are properly filed according to that method. If the wrong method is selected, even if all the required documents are submitted, the taxes cannot be refunded.
Qihang Zhilian Foreign Trade Research Institute·Let China's intelligent manufacturing industry set sail to sea·Tel: 180-0327-6609
