“Spending 50 to 200 yuan to buy a customs declaration header can save more than half a year of time in obtaining the necessary qualifications, and you don’t have to worry about invoices and tax refunds”—this “buying export documents” model, once considered a “shortcut” by many small and micro foreign trade enterprises, is rapidly fading from the historical stage under the heavy blow of the regulatory policies introduced in 2025. From the severe punishment of four Shenzhen companies for defrauding nearly 30 million yuan in taxes to the sentencing in Ningxia’s first case of fabricating export subsidies, a series of typical cases have revealed the profit chain and deep-seated harm of this gray model. The joint rectification by five departments and the implementation of new tax regulations further signify the arrival of an era of “compliance awakening” in the foreign trade industry. I. Gray Market Operations: From a “Workaround” to a “Criminal Chain” The core of “buying export documents” is that cargo owners without import/export qualifications pay fees to qualified companies, using their names to declare exports, creating an illegal situation where the “flow of goods, flow of funds, and flow of documents” are disconnected. In the early years, due to strict foreign trade qualification controls, this model became a workaround for small and micro-sized businesses and cross-border e-commerce companies to cope with the difficulties of “small orders, mixed goods, and no invoices”—obtaining qualifications takes 3-6 months, while the fee for buying export documents only accounts for 0.1%-0.5% of the value of the goods, reducing overall costs by 8%-15%, suitable for small-batch, multi-SKU export demands. With the introduction of local export subsidy policies, buying export documents has gradually degenerated into a tool for transferring benefits. In some areas, a reward of 0.03-0.05 yuan for every 1 US dollar received has spawned an industry chain of “shell companies buying data to receive subsidies.” In one southwestern province, over 100 shell companies were investigated and found to have fraudulently obtained over 200 million yuan in subsidies. In a more covert tax fraud scheme involving “buying invoices and matching them with receipts,” a criminal gang in Shenzhen defrauded export tax refunds of 29.6138 million yuan by issuing false invoices and fabricating foreign exchange settlements, ultimately resulting in the recovery of 90.0066 million yuan in fines.
II. Multi-dimensional Driving Forces: The Dual Push of Corporate Profit-Seeking and Local Government Performance
At the enterprise level, the allure of low barriers to entry and low costs is the core motivation. Small and micro foreign trade enterprises and cross-border e-commerce businesses do not need to equip themselves with professional customs declaration and tax teams, nor do they need to advance tax refund funds. Especially when the tax refund rate is low or there are no input invoices, they can directly bypass the compliance costs of issuing invoices.
At the market level, freight forwarders and customs brokers have formed a complete industrial chain of “order seeking – order processing – customs declaration – payment collection,” profiting from the price difference by integrating resources from unqualified cargo owners and shell companies. The explosive growth of the cross-border e-commerce industry has further amplified the demand for small-batch, high-frequency purchase orders. At the local level, some regions use export volume as a core performance indicator, tacitly approving or even dominating the practice of purchasing export orders. In one case, a local commerce bureau official used WeChat to manipulate customs declaration volume to meet the “opening red” performance assessment. This “data-driven, results-oriented” approach leads to distorted foreign trade data and breeds opportunities for rent-seeking. In March, five departments jointly issued Announcement No. 8, listing fictitious exports and the buying and selling of customs declarations as key targets for crackdown. In July, the State Taxation Administration issued Announcement No. 17, revising the declaration form and requiring export agents to submit information on the actual cargo owners; otherwise, they would have to bear the corporate income tax themselves, thus closing the loophole of “registration-tax evasion-cancellation.” The Golden Tax System Phase IV has achieved data interoperability with the customs smart audit platform, establishing an early warning model for shell companies with “short duration, zero declarations, and high export volume.” Through comparison of consistency of three flows (information, capital, and goods), penetrating verification is achieved. Cases solved in Shenzhen, Ningxia, and other places have benefited from cross-departmental data linkage. The cost of violations has surged. Shell companies may need to pay 25% corporate income tax, and cargo owners may be treated as domestic sellers and pay 13% value-added tax and late payment fees. The tax and late payment fees for exporting 1 million yuan worth of goods may exceed 400,000 yuan, far exceeding the cost of purchasing the goods. IV. Compliance Transformation: A Transparent Channel Becomes a Must for Foreign Trade Enterprises Following the release of Announcement No. 17, the “Shicaitong” platform, focusing on market procurement trade, saw its system traffic increase tenfold and its contract signings surge. Its one-stop service for “export without invoices, compliant foreign exchange receipts, and convenient customs clearance” has become the preferred choice for the transformation of over 40,000 small and micro foreign trade enterprises, with cumulative export volume exceeding 90 billion yuan. Enterprises without qualifications can entrust legitimate foreign trade service companies to act as agents or complete registration for self-declaration; enterprises without input invoices can choose models such as 1039 market procurement and 9810 cross-border e-commerce to enjoy “tax exemption without invoices”; enterprises with existing business need to establish internal control processes that ensure consistency between “invoices, goods, and payments.” The Dongguan tax authorities remind enterprises with historical payment transactions to proactively rectify outstanding accounts and taxes to reduce the risk of retroactive penalties. V. Industry Restructuring: Saying Goodbye to Gray Market Profits and Moving Towards a New Stage of Compliance-Driven Success Various regions are gradually shifting from a “sole criterion for success” to a comprehensive evaluation based on “output value, employment, and tax revenue,” eliminating the waste of public funds on falsified data. Cases in Ningxia, Shenzhen, and other places have already served as accountability warnings to relevant personnel. As policy barriers continue to strengthen, the space for export through third-party payment has been thoroughly squeezed, and the foreign trade industry is bidding farewell to “gray market profits” and entering a new stage of “compliance-driven success.” Only by focusing on product development and optimizing services, and developing in a transparent manner, can enterprises achieve long-term development in international trade. This industry restructuring triggered by regulatory reforms will ultimately propel China’s foreign trade towards a higher quality and more sustainable direction. Compliance has changed from an “optional question” to a “must-answer question” for the survival and development of enterprises.
