Cross-border E-commerce Export Tax Fraud Case: Using 9810 and Other Models to Forge Documents for Illicit Tax Refunds

Who Gets Targeted

The primary victims are the national tax order and compliant cross-border e-commerce enterprises. Criminals exploit the weaknesses of small and medium-sized cross-border e-commerce firms—specifically their urgent need for cash flow, weak tax compliance awareness, and lack of familiarity with export tax rebate procedures—to induce them into participating in 'buying documents' or fabricating export transactions. Simultaneously, national export tax rebate funds are directly eroded, severely disrupting fair competition in the cross-border e-commerce industry.

骗局怎么运作

• Registration of Shell Companies and Acquisition of Qualifications: Fraud rings first register large numbers of shell companies with no actual business operations, or acquire failing foreign trade companies that possess export tax rebate qualifications at low prices. By controlling these entities, they establish interfaces with customs and tax authorities, laying the groundwork for forging documents to claim tax refunds.
• Fabricating Export Transactions and Forging Documents: Under cross-border e-commerce models like 9810 (overseas warehouses), the rings collude with freight forwarders to forge export customs declarations, logistics bills of lading, and warehousing certificates. Through 'document buying' operations, they bundle small, non-tax-rebate-eligible orders into large-scale export transactions to create the illusion of legitimate exports.
• Issuing Fraudulent VAT Special Invoices: To meet the input invoice requirements for export tax rebates, fraud rings illegally purchase or have others issue fraudulent VAT special invoices. They typically establish fake supply chain links in the locations of the involved enterprises or in tax havens, fabricating records of raw material procurement or product processing to artificially inflate input tax amounts.
• Fabricating Capital Flows and Foreign Exchange Verification: To cover up fake transactions, the rings use underground banks or cross-border payment channels to facilitate capital repatriation. They use domestic and offshore accounts to swap foreign exchange, creating fake transaction records of payments from foreign buyers to satisfy the foreign exchange management department's requirements for collection and verification, thereby creating a closed loop for the entire set of export tax rebate documents.
• Centralized Filing to Claim Tax Refunds: Once all forged documents are ready, the rings submit tax refund applications to tax authorities via electronic tax bureaus or offline counters. Exploiting the time lag in tax audit workflows and the blind spots of frontline auditors, they quickly siphon off massive tax refunds. Once the funds are received, they are immediately transferred, laundered, or the shell companies are dissolved.

红旗信号（看到这些快跑）

• 🚩 An abnormal, explosive surge in export volume over a short period, while actual warehousing, logistics, and labor costs are completely inconsistent with the export scale, indicating a typical 'export without actual business' scenario.
• 🚩 Input invoices are concentrated from recently established micro-enterprises, with significant discrepancies between the invoiced product names and actual export goods, or a lack of genuine logistics and capital flow records in the supply chain.
• 🚩 Exported goods are mostly low-value-added items, yet the declared tax rebate amounts are disproportionately high, and customs clearance occurs at ports far from the company's registered location, showing clear signs of 'detour' customs clearance.
• 🚩 Capital account flows show 'fast-in, fast-out' patterns; after receiving remittances from foreign buyers, funds are quickly split and transferred through multiple personal or related accounts, and the accounts used to forge foreign exchange receipts have no direct connection to the actual overseas buyers.
• 🚩 Frequent changes in legal representatives and registered addresses, with the actual controller hiding behind the scenes and the company lacking physical office space or employees, operating solely as a shell tool for tax fraud.

真实案例

• In 2026, Shenzhen reported a major cross-border e-commerce 9810 tax fraud case. A criminal ring used the overseas warehouse export model to fabricate transactions, forging customs declarations and issuing fraudulent invoices to claim export tax rebates. The case involved over 53 million yuan, and 18 suspects were eventually transferred to the procuratorate for prosecution.
• In July 2026, the Supreme People's Procuratorate reported a case involving tax fraud through the falsification of goods. Criminals forged export documents and organized fake supply chains to illicitly claim 238 million yuan in national export tax rebates. The primary culprits have been legally prosecuted.
• The State Taxation Administration's Tianjin Municipal Tax Bureau publicly exposed details of several illegal export tax rebate fraud cases in 2026. A foreign trade company used illegal means such as 'buying documents' to siphon off national tax rebates, triggering a crackdown by tax audit departments and resulting in the downgrading of the company's qualifications.

Official Stance

• On February 27, 2026, the Tianjin Municipal Tax Bureau of the State Taxation Administration publicly released investigation details, exposing 4 cases of illegal export tax rebate fraud and warning enterprises not to participate in tax fraud using fake documents.
• On July 21, 2026, the Supreme People's Procuratorate of the People's Republic of China issued a report on a 238 million yuan tax fraud case involving the falsification of goods, noting that such behavior severely endangers the tax order.
• On January 8, 2026, CCTV and the State Taxation Administration jointly exposed 6 cases of illegal activities by tax intermediaries, cracking down on the grey industry chain where intermediaries participate in issuing fraudulent invoices and facilitating export tax rebate fraud.

How to Protect Yourself

• ✅ Cross-border e-commerce enterprises should strictly audit their supply chain, ensuring that suppliers of input invoices have genuine production capacity, and must never accept fraudulent VAT special invoices without a background of actual goods transactions.
• ✅ Enterprises need to improve the authenticity documentation for overseas warehouse export operations, properly preserving logistics tracking, overseas warehouse entry certificates, and final sales records to ensure the entire export business chain is authentic and traceable.
• ✅ Finance and compliance departments should closely monitor tax audit requirements for new models like cross-border e-commerce 9810. If suspicious freight forwarders or tax intermediaries offer 'guaranteed tax rebate' services, they should decisively refuse and retain evidence.
• ✅ Tax agencies and freight forwarders should establish strict client due diligence mechanisms, refusing to provide 'document buying' or fake foreign exchange swap services for companies without actual export business, and must not become accomplices in export tax rebate fraud.