1. Overseas warehouse exports: refund on departure
Under current tax rules for overseas-warehouse exports (customs supervision code 9810), goods may be declared for export tax refunds once they have cleared customs and left the country. Where the goods are not yet sold, a pre-refund may be filed under the "refund on departure, settle after sale" approach, with a later reconciliation against actual sales. For factories running overseas warehouses this is a direct cash-flow improvement. Always confirm details with your competent tax authority and the latest public notices.
2. Pilot zones: exemptions and assessed levies
- Qualified retail exporters in pilot zones may trial VAT and consumption-tax exemption on goods exported without valid purchase documentation
- Qualified cross-border e-commerce enterprises may use assessed corporate income tax, with a unified taxable income rate of 4%
- Where valid input documentation exists, exporters can obtain customs declarations via list-based release and consolidated filing, then claim refunds
3. Faster refunds: paperless processing
Authorities are rolling out fully paperless export refund processing for eligible category 1-3 exporters, and some regions run pre-refund whitelists targeting much shorter cycles. The prerequisite is complete books and properly archived documentation.
4. New channel combinations
In 2026, commerce authorities issued guidance on high-quality e-commerce development that explicitly supports combined models such as market procurement plus cross-border e-commerce, and China-Europe rail plus cross-border e-commerce, alongside overseas warehouse and smart logistics platforms. Traditional exporters should test these channels against their category and destination.
5. Three prerequisites
- Real transactions, complete documents - contracts, invoices, declarations and FX receipts must reconcile
- Declaration mode matches reality - do not mix 0110/9610/9710/9810, and avoid bought-in export declarations
- Sunlight FX routing - netting overseas expenses against export proceeds requires genuine evidence
Note: policy details change. This is a directional summary - verify against the latest notices from tax, customs and commerce authorities before acting.
6. What factories should do next
Run a policy check-up: classify the last twelve months of exports by supervision code, look for benefits you were entitled to but never claimed, and check for mismatched declaration modes. Then evaluate pilot-zone and overseas-warehouse routes per target market. For most factories the first step is not claiming a subsidy - it is fixing the paperwork.
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Is 9810 pre-refund right for every factory?
It suits overseas-warehouse models where goods leave before sale. Order-based direct shipping follows its own supervision code - confirm with your tax authority.
How is the 4% taxable income rate applied?
When eligible cross-border e-commerce enterprises use assessed corporate income tax, the taxable income rate is set at 4%. Eligibility depends on entity type and local rules - verify locally.
No input invoices means no refund at all?
Not necessarily. Qualified enterprises in pilot zones may apply exemption policies instead, but thresholds and procedures differ. Ask your tax office rather than assuming.