Since 2026, the fourth phase of the Golden Tax has fully penetrated supervision, and tax, customs, foreign exchange, and bank data have been interconnected in real time, forming a closed loop of full-chain verification of “goods flow, logistics, ticket flow, and capital flow”.
What an accountant who handles export tax refunds fears most is not the complexity of the process, but “being inexplicably warned.”
Small operations that seemed “inconsequential” in the past will now trigger an early warning as soon as they are touched. The follow-up process will be verification, correspondence, tax repayment, fines, and in serious cases, tax refund rights will be suspended and criminal liability will be pursued.
The following are 5 high-frequency behaviors that will trigger warnings once triggered in export tax rebates:
Behavior 1: Document information is inconsistent, and a warning will be issued if there is one word difference (most common)
This is the most common and most easily ignored warning trigger point, and it is also the primary target for big data comparison.
Common violations include inconsistency between the name of the customs declaration item and the name of the special VAT invoice, confusion of units, mismatch of specifications and models with the contract, artificial modification of HS codes, etc.
For example, a cross-border e-commerce company in Guangdong applied for advance tax refund under the 9810 model. There was only a two-character difference between the name of the customs declaration item “pure cotton sweatshirt” and the input invoice “sweatshirt”. The company tried to forge a supplementary agreement to cover up the difference, which directly triggered an audit warning. The tax refund was rejected, and it was also included in the list of companies of concern. The follow-up review period was extended to 6 months.
The consequence of the early warning is that the system will automatically intercept the tax refund and suspend the tax refund; if the doubtful points cannot be eliminated, the tax refund will not be granted and will be regarded as tax repayment for domestic sales; long-term abnormalities will be classified as high-risk enterprises, and subsequent inspections will be focused on the entire declaration process.
The compliance approach is to carefully check all documentary information before customs declaration to ensure that the customs declaration, invoice, contract, and bill of lading are “consistent with the documents and documents.” The HS code is classified according to the actual material and purpose of the goods and is not modified at will.
Behavior 2: False issuance/acceptance of false invoices, fraud in the tax refund chain (the red line among the red lines)
False issuance of invoices is the core means of export tax refund fraud, and it is also the key behavior to be cracked down on in the fourth phase of the Golden Tax.
Common violations include asking suppliers to issue false invoices for genuine procurement business, falsely increasing the purchase amount, accepting abnormal invoices, introducing others to falsely issue invoices, etc.
For example, a foreign trade company in Zhejiang forged purchase contracts, falsely issued special VAT invoices, and used false customs declarations to declare tax refunds through associated shell companies. The amount involved exceeded 8 million yuan. The system immediately issued an alert after comparing abnormal inputs and cargo flows. It was ultimately determined to be tax fraud. The company was required to pay taxes + 1 times the fine, the legal person was sentenced, and the accountant was jointly and severally liable.
The consequences of the early warning are that false tax payment of more than 10,000 yuan constitutes a crime and will be investigated for criminal responsibility; tax refunds for downstream companies are suspended, temporarily withheld, and recovered, the companies are blacklisted, and legal persons and accountants are banned from the fiscal and tax field for life; for more than two violations, export goods will be changed to a tax-free policy.
Compliance practices are to only accept invoices with real business support, check supplier qualifications before purchasing, and confirm that their taxes are normal; verify invoices in a timely manner after receiving them, reject or void them immediately if any abnormalities are found, and not participate in any false invoicing behavior.
Behavior 3: Abnormal foreign exchange collection, unregistered third party/false foreign exchange collection
Foreign exchange collection is an important prerequisite for export tax refunds. In 2026, the foreign exchange management and tax authorities will verify the foreign exchange collection information one by one. Abnormal foreign exchange collection has become a high-frequency early warning point.
Common violations include failure to collect foreign exchange in accordance with regulations and still claiming tax refunds without meeting the conditions for deemed foreign exchange collection, collecting foreign exchange through third-party accounts without reasonable reasons, and forging foreign exchange receipts, etc.
For example, after a foreign trade company exported goods, it used an underground bank to forge foreign exchange collection records to declare tax refunds. The foreign exchange collection funds quickly flowed back to the company’s private accounts in a short period of time. The system detected abnormal fund flow and triggered an early warning. It was eventually determined to be false foreign exchange collection, and the refunded tax was fully recovered, and a fine of 1 to 5 times was imposed.
The consequence of the early warning is that tax refunds will not be granted and refunded taxes will be recovered; those suspected of money laundering and tax fraud will be transferred to the public security department for processing; if foreign exchange is not collected as required and there is no compliance filing, the value-added tax exemption policy will apply to exported goods, and the input tax will be included in the cost.
The compliance approach is to collect foreign exchange within the specified time limit. If the foreign exchange cannot be collected on time, evidence materials must be prepared in advance and deemed to be a foreign exchange collection record as required. Third-party foreign exchange collection and offshore foreign exchange collection must be filed in advance and proof of reasonable business reasons must be retained to ensure that the flow of funds is clear and traceable.
Behavior 4: Paying orders and matching invoices, false exports, fictitious business chains
“Paying orders and matching invoices” is a typical method to defraud export tax refunds. With the implementation of the real-name system for agent exports and customs data networking, this behavior has no room for survival.
Common violations include using other people’s documents for exporting genuine goods and using false invoices to declare tax refunds, and pretending to export goods for domestic sales, etc.
For example, during the pilot period in December 2025, Shenzhen Customs intercepted 127 cases of suspected pay-for-export cases, involving goods worth over 230 million yuan. All relevant companies were triggered with early warnings, and were subsequently required to pay back taxes and fines. Some companies had their export tax refund rights suspended for more than 3 years.
The consequences of early warning are full recovery of tax refunds + late payment fees + 1 to 5 times fines; suspension of export tax refund rights for 3 years or even permanently; cases of tax fraud of more than 50,000 yuan are filed. If the amount is larger, the person may be sentenced to fixed-term imprisonment of not more than 5 years; if the circumstances are particularly serious, the person may be sentenced to life imprisonment.
The compliance approach is to only engage in real export business and not participate in illegal operations such as billing, affiliation, and agency; entrusted exports must go through formal agency registration and retain a full set of real business information to ensure traceability of the business.
Behavior 5: Missing, fake or overdue documents
Many accountants ignore the filing and retention of documents. Documents are the core basis for tax refund verification. Missing, fake or overdue documents will directly trigger early warnings.
Common violations include failure to retain the filing documents as required after declaring a tax refund, forging and altering the filing documents, failing to file the filing documents on time or having insufficient retention periods, etc.
For example, due to financial negligence, a garment company in Shandong lost its export registration documents and failed to file them as required. Although the export business was genuine, the system detected that the documents were missing and triggered an early warning. In the end, the tax refund + 0.5 times the fine was recovered, resulting in a loss of more than 2 million yuan.
The consequences of the early warning are that tax refunds are suspended and can only be resumed after passing the rectifications; the refunded tax will be fully recovered and deemed to be sold domestically; those who have forged documents will be treated as an accomplice in tax fraud and face fines and criminal liability; the verification can be traced back to 10 years, and old accounts may be turned over at any time.
The compliance practice is to organize and archive the complete set of filing documents in order within 15 days after applying for tax refund, make a directory of filing documents, and make electronic and paper backups. The storage period is not less than 10 years and must not be damaged or lost without authorization.
Core points for responding to early warnings in 2026
1. Early warnings are no fluke: penetrating comparison of the fourth phase of the Golden Taxation data, any irregularities cannot be hidden, and do not have the mentality of “it doesn’t matter once in a while”;
2. Self-examination should be timely: before monthly settlement, check documents, foreign exchange collections, invoices, and capital information item by item, and detect abnormalities in advance to avoid triggering early warnings;
3.
There are ways to remedy the situation: once an early warning is triggered, don’t panic. Submit supporting information as required by the tax authorities, explain the true situation, and cooperate with the verification. If the business is genuine, tax refunds can be resumed normally;
4. The bottom line must be kept: resolutely avoid red lines such as false invoicing, paying orders and allocating invoices, false collection of foreign exchange, etc. Accountants must dare to refuse the boss’s illegal requests, retain relevant evidence, and avoid taking the blame.
Export tax rebates are policy bonuses given by the state to foreign trade companies, but they are by no means “Tang Monk Meat”.
Regulation will become increasingly strict in 2026, and “compliance” is the only way out.
