I. Global Trend of Tightening Tax Regulation

United States: From January to August 2025, U.S. Customs (CBP) uncovered tax evasion cases totaling $400 million, with 23 Chinese shell companies investigated for avoiding tariffs through transshipment via third countries.

China: The State Taxation Administration issued Announcement No. 15 of 2025, requiring internet platforms to quarterly report merchants’ identity and income data to tax authorities, marking the formal implementation of the “three-in-one穿透式” regulation (platform, income, and identity穿透).

Europe: German tax authorities demanded sellers pay back VAT taxes for 2018-2021 (amounts ranging from 420,000 to tens of millions of yuan), with even deregistered entities being pursued.

II. Typical Cases and Penalty Outcomes

Shenzhen E-commerce Company: Penalized for concealing income, resulting in back taxes of 56.7185 million yuan and a fine of 39.0307 million yuan, totaling 95.7492 million yuan.

Liaoning Company: Fabricated export operations to fraudulently obtain export tax rebates of 212 million yuan, resulting in recovery of the rebates and an equivalent fine.

Shenzhen Company: Exported “lead-acid batteries” under the name “lithium batteries” to fraudulently obtain export tax rebates of 149 million yuan, resulting in recovery of the rebates and a fine of 100% of the amount.

III. Common Industry Issues and Risks

Issuing fraudulent invoices (especially VAT special invoices, which can carry a maximum sentence of life imprisonment).

Concealing income (uninvoiced revenue not recorded or declared).

Maliciously splitting income, engaging in “buying export orders,” falsifying tax IDs and prices.

Export tax rebate fraud (forging documents, misrepresenting product names, etc.).

IV. New Regulatory Requirements

China Announcement No. 15: Platforms must report merchant identities, quarterly income (including refunds), and related-party information (e.g., relationships between livestreaming agencies and hosts). Domestic agents of overseas platforms must also comply.

China Announcement No. 17: Export agents must submit the “Summary of Entrusted Export Situations of Export Agency Enterprises.” Incorrect identification of the actual cargo owner may result in a 13% VAT supplement.

U.S. IRS: E-commerce sales are a key enforcement area. Sellers using FBA warehouses or registering U.S. trademarks are subject to income tax (non-filers may face a 30%核定 tax on sales and retrospective payments for multiple years).

Europe VAT: Strict historical tax recovery, with entities pursued even after deregistration.

V. Industry Response and Summit Initiatives

Lingxing Cross-Border E-commerce Summit (September 17, Shenzhen) focuses on compliance strategies, including:

Compliance paths under global regulatory tightening (shared by Deloitte tax partner).

Dimensions such as global brand expansion, AI technology, and capital insights.

Expected participation of 3,000+ cross-border enterprises to discuss strategies for breaking growth bottlenecks.

Core Conclusion:

Cross-border e-commerce has entered an era of “comprehensive compliance.” Global regulations are tightening with enhanced穿透式 measures. Enterprises must avoid traditional violations (e.g., tax fraud, income concealment), proactively adapt to new rules, and seek compliant development paths through industry collaboration.

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