Editor's Note: The successive implementation of the "Announcement on Optimizing Matters Related to Enterprise Income Tax Prepayment Filings" (2025, No. 17) and the "Internet Platform Enterprise Tax-Related Information Reporting Provisions" is having a profound impact on the cross-border e-commerce sector. This is particularly evident after Amazon's public notification that it will quarterly report information related to Chinese sellers to the Chinese tax authorities, leading to many cross-border sellers receiving self-inspection notices from the tax authorities. This signifies that the new rules, through "information penetration" and "joint liability" mechanisms, have enabled the integration of tax authority data with internet platform data, fundamentally altering the tax regulatory logic for cross-border e-commerce export businesses. This article will analyze the tax challenges and response strategies faced by cross-border e-commerce from three dimensions: new regulations, risk identification, and compliance recommendations.

I. New Regulations Forge a Full-Chain Supervision System, Challenging the "Declaration Purchase Export" Model

(I) Enterprise Income Tax Prepayment New Rules – Export Customs Declaration Supervision

The "Announcement on Optimizing Matters Related to Enterprise Income Tax Prepayment Filings" (State Administration of Taxation Announcement 2025 No. 17, hereinafter "Announcement No. 17") officially took effect on October 1, 2025. The new rules explicitly require that export enterprises involved in agency businesses must not only declare export agency fee income as operating revenue but also accurately report the information of the actual principal during the prepayment phase. Failure to fulfill these reporting obligations will result in the relevant agency export business being treated as self-operated, making the agency enterprise liable for the corresponding enterprise income tax. This regulation imposes new compliance requirements on cross-border e-commerce sellers who traditionally relied on "Declaration Purchase Export" to ship goods overseas.

(II) Internet Platform Tax Information Reporting New Rules – Online Income Transparency

The implementation of the "Internet Platform Enterprise Tax-Related Information Reporting Provisions" and supporting tax policies marks the formal integration of platform operators' sales revenue into the normalized tax supervision system. The new rules explicitly require domestic and foreign internet platform enterprises to regularly report identity information and income data of operators on their platforms to the tax authorities. Key income indicators include total sales including tax, refund amounts, and net income.

As of October 15, over 6,654 domestic and foreign platforms had reported their basic information, and more than 4,100 platforms had reported tax-related information of operators and practitioners on their platforms. The sales revenue data reported by platforms will be cross-referenced with goods flow information centered on customs declaration forms. Significant discrepancies between the two will become crucial leads for tax audits.

(III) CRS Tax Information Exchange Mechanism – Overseas Fund Monitoring

The acceleration of global tax transparency, facilitated by the Common Reporting Standard (CRS) mechanism, provides institutional safeguards for monitoring the capital flows of cross-border e-commerce. According to OECD statistics, by 2024, tax authorities in 111 jurisdictions were automatically exchanging financial account information. In 2023, information on over 134 million financial accounts was exchanged, involving total assets of nearly €12 trillion. Among these, 106 jurisdictions have committed to and practically implemented information exchange with Mainland China, covering major transit and destination points for cross-border e-commerce fund flows.

Through CRS information exchange, the Chinese tax authorities can access information about accounts held by residents in overseas financial institutions. When the scale of funds in overseas accounts significantly mismatches declared domestic income, it easily raises questions from tax authorities regarding the completeness of overseas income declarations.

Summary: Combined with the enterprise income tax prepayment rules and platform information reporting requirements, the CRS mechanism completes a comprehensive supervision system covering the "flow of goods, flow of funds, and flow of information," marking the entry of cross-border e-commerce tax supervision into an era of transparency.

II. Multiple Tax Risks Coexist for Export Agency Enterprises and Cross-border E-commerce Sellers

Under the transparent regulatory environment established by the new rules, export enterprises, cross-border e-commerce sellers, and the individuals behind them, as key subjects in the complete responsibility chain, face significant compliance challenges and legal risks.

(I) Export Enterprises: Increased Responsibility for Agency Export Businesses

The introduction of Announcement No. 17 signifies an important shift in the role of export agency enterprises. Regarding enterprise income tax, if an agency enterprise fails to fulfill its statutory information reporting and verification obligations, the relevant export business will be treated as self-operated, and it will be liable for enterprise income tax on the full export value.

Regarding value-added tax (VAT), if export business is identified as "Declaration Purchase Export" or completed using false documentation, the tax authorities may determine that the export does not qualify for export tax refund (exemption) policies and should instead be subject to VAT according to the rules. This means the relevant export business may be treated as domestic sales, requiring VAT to be paid accordingly.

Furthermore, if the exported goods involve tax refunds, export enterprises may also face the risk of being implicated and bearing criminal liability for fraudulent export tax refunds. Under the Declaration Purchase Export model, agency enterprises providing export qualifications may be identified as accomplices in fraud.

(II) Cross-border E-commerce Sellers: Compliance Pressure from Full-Chain Data Transparency

For cross-border e-commerce sellers, the compliance challenges under the new regulatory environment are more systematic. Firstly, the "Declaration Purchase Export" model is no longer sustainable. The sales revenue reported by platforms, overseas fund flows exchanged via CRS, and export values recorded by customs form a complete evidence chain. Data inconsistencies can trigger tax audits. Secondly, the widespread issue of missing invoices in the procurement process leads to a lack of cost vouchers, affecting not only VAT input credit but also potentially leading to insufficient pre-tax deduction for enterprise income tax, resulting in risks of back taxes and late payment penalties. More importantly, in a fully transparent regulatory environment, the risk of retrospective audits for historical issues like income splitting and abuse of tax incentives increases significantly. Tax authorities have the power to make tax adjustments for arrangements lacking reasonable business purpose.

(III) Individuals Behind Cross-border E-commerce Sellers: Legal Liability in the Fund Repatriation Link

Against the backdrop of a formed regulatory closed loop, the actual controllers, major shareholders, and related individuals behind enterprises also face legal risks. Using personal accounts to receive sales proceeds may not only be deemed as concealing enterprise income but also places the burden of proof regarding the nature of the funds on the individual. If the legal source of the funds cannot be proven, it may lead to risks of recovering individual income tax. In cases where the enterprise is suspected of tax evasion, actual controllers and directly responsible personnel may bear corresponding administrative liability, even facing criminal risk. Simultaneously, cross-border fund flows through illegal channels may also involve other legal risks.

III. Compliance Recommendations: Moving from Risk Avoidance to Compliance Management

Facing an increasingly strict regulatory environment, it is recommended that relevant market participants start addressing the issue from the following aspects:

(I) Promote Fundamental Transformation of Business Models

Enterprises are advised to carefully select and establish compliant export entity identities based on their scale and qualifications, gradually moving away from the traditional reliance on "Declaration Purchase Export." Eligible sellers can explore compliant export methods suitable for small-value, multi-batch businesses, such as "Market Procurement Trade" and "Export to Overseas Warehouses," including establishing their own export entity status and standardizing the use of cross-border e-commerce export supervision codes.

(II) Establish a Business Authenticity Verification Chain

In internal management, efforts should be made to build a complete business authenticity verification system. Ensure that throughout the entire process from contract signing, goods delivery, fund payment and receipt, to invoice issuance, the business flow, contract flow, goods flow, fund flow, and invoice flow are interconnected and mutually verifiable.

(III) Proactively Conduct Health Checks and Risk Isolation

Considering the retrospective power and penetrating nature of the new regulations, enterprises are advised to conduct necessary compliance assessments of historical businesses to accurately identify and quantify potential risks. Based on this, targeted solutions can be developed in cooperation with professional institutions, striving to resolve historical issues compliantly within the regulatory window period.

IV. Summary

The implementation of the 2025 Enterprise Income Tax Prepayment Rules and the Platform Tax Information Reporting Provisions marks a fundamental shift in cross-border e-commerce tax supervision from "managing tax based on invoices" to "managing tax based on data." Through the "information penetration" and "joint liability" mechanisms, the new rules have built a full-chain supervision network covering the flow of goods, funds, and information.

For the industry, this is both a period of adjustment for traditional business models and an opportunity for standardized development. Export enterprises face the risk of increased responsibility, cross-border e-commerce sellers need to cope with the compliance pressure brought by full-chain data transparency, and the individuals behind them also face legal liabilities in the fund repatriation process.

In the long run, unified regulatory standards and a transparent tax environment will help create a fair competition order and promote the healthy development of the industry. It is recommended that relevant market participants actively adapt to regulatory requirements, integrate tax compliance into all aspects of operations, and enhance compliance management levels through business model optimization and improvement of internal control mechanisms.