Recently, the tax inspection storm in Shenzhen’s freight forwarding industry has made foreign trade companies that have long relied on “paying exports” anxious.
The fourth phase of the Golden Tax big data supervision has been fully implemented. In the past, the gray operating model of borrowing other people’s import and export qualifications and making customs declarations without tickets faced serious risks such as tax repayment, late payment fees and even criminal liability.
The core risks of paying for exports are “qualification borrowing” and “tax deficiency”.
If an enterprise purchases someone else’s customs declaration form for export, it will not only face customs verification of the authenticity of the customs declaration subject. Under the data flow monitoring of the fourth phase of the Golden Tax, mismatches between capital flow, goods flow and invoice flow can be easily identified.
Once audited, the company will need to pay back value-added tax, surcharges and high late fees. In serious cases, it may also involve criminal issues such as smuggling or false invoicing. This lucky business model can no longer adapt to the regulatory environment.
The 1039 market procurement trade policy provides a legal path for uninvoiced export enterprises.
Its core advantage is the “double-headed customs declaration” model. After an enterprise registers an individual industrial and commercial household in the pilot area, it cooperates with a qualified trade operator to declare customs in a “double-headed customs declaration” mode of “individual industrial and commercial household + trading company”.
This model allows companies to legally declare exports without input invoices and enjoy the VAT exemption policy, which solves the compliance pain points of paying for exports.
The foreign exchange collection and settlement under the 1039 mode is safer. The funds are directly transferred into the accounts of individual industrial and commercial households. The collection of foreign exchange from public or private parties is in compliance with policy requirements, avoiding the risk of freezing or misappropriation of foreign exchange collection during export payment.
Comparing the pay-for-export and 1039 models, the differences are obvious.
In terms of customs declaration entities, paying the bill is borrowing other people’s qualifications, and 1039 is a legal double header; in terms of tax compliance, there is no policy support for paying the bill, and 1039 enjoys tax exemption; in terms of foreign exchange security, paying the bill relies on third-party accounts, and 1039 funds go directly to one’s own account; in terms of long-term development potential, the paying model is unsustainable, and 1039 helps enterprises establish compliance systems, laying the foundation for branding and scale.
The operation process of transformation 1039 is clear and controllable.
First register individual industrial and commercial households in pilot areas such as Yiwu and Guangzhou, then select trade operators with 1039 qualifications as agents, complete customs declarations through double headers, and finally collect and settle foreign exchange in compliance with the individual industrial and commercial household accounts.
In practice, attention should be paid to the differences in policies in the pilot areas, the integrity of qualification application materials, and the standardized use of the electronic ledger system. The system can manage tax data in real time to ensure compliance. Enterprises can also enjoy tax rebate bonuses in the pilot areas and reduce costs.
Foreign trade companies should say goodbye to the fluke mentality of paying for exports and embrace the 1039 compliance model, which is an inevitable choice to achieve long-term development.
1039 not only solves current regulatory risks, but also helps companies establish standardized operating systems and enhance market competitiveness. Compliance management is the cornerstone of a company’s stable and long-term development.
