Payment for export "is a well-known operation method among many sellers, which refers to the process of purchasing export documents from other companies with export rights (including invoices, packing lists, customs declaration letters, verification forms, and special certificates) in the name of the exporting company when the exporting party does not have export rights or does not want to use their own company's name on the export documents.

Simply put, it means borrowing someone else's company name and export documents to complete customs clearance procedures.

However, 'paying for exports' is actually not compliant and has a high probability of triggering illegal activities such as tax evasion, certificate evasion, and illegal foreign exchange transactions.

Now, with the increasing number of problems caused by the operation of "paying for export", the tax bureau has strengthened its review of this model, questioned the compliance of export enterprises' declaration, and asked relevant enterprises to show the qualification certificate of agency declaration, otherwise they will face the requirement of tax compensation.

Since last year, industry insiders have been advising sellers to avoid continuing to use the high-risk "pay to export" method, as although this approach may seem convenient, its potential consequences are quite serious and involve extremely high potential risks.

Some sellers have expressed that the customs clearance at Qingdao Port is almost checked by invoice, and hundreds of containers have already been seized. Therefore, export sellers must act cautiously and comply with customs clearance regulations. Once the inspection is completed, it will be time-consuming and laborious, and the cost will not be worth the loss.

Recently, customs and tax authorities in various regions have released their "performance".

Many Shenzhen export enterprises have been subject to tax inspections by the Shenzhen Taxation Bureau. The reason for the inspection is that the exported products are not eligible for export tax refund (exemption) policies and have failed to truthfully declare sales. The cross-border export enterprise exported through the "pay and declare" method and was required by the tax authorities to make up for the tax payment within a specified period of time.



The notification content shows that your (unit) exported goods in 2021, 2022, 2023, and 2024 are not eligible for export tax refund (exemption) policies, and you did not truthfully declare the sales amount when declaring. You (unit) are required to complete the correction declaration and pay the tax within 15 days from the date of receiving this notification.



In addition, the number of cases of fraudulently obtaining export tax refunds that have been investigated and dealt with in accordance with the law is also quite considerable.

Some time ago, the Shenzhen Taxation Bureau, together with the economic investigation department of the public security, investigated and dealt with a gang case of defrauding export tax rebates according to law, pushed down one gang of tax fraud, and arrested seven suspect. After investigation, the gang controlled a total of 5 export enterprises and fraudulently obtained export tax refunds through methods such as payment and ticket allocation, false foreign exchange settlement, etc. According to relevant regulations, the Shenzhen Taxation Bureau has recovered 5 export enterprises for fraudulently obtaining export tax refunds of 31003600 yuan, refused to refund 7.213 million yuan, supplemented other taxes totaling 30719300 yuan, and imposed a fine of 31003600 yuan. The Intermediate People's Court of Shenzhen, Guangdong Province, has made a first instance judgment on the case. The main offender, Wu, was sentenced to ten years in prison and fined 31003600 yuan for the crime of defrauding export tax refunds.



Judging from the cases exposed in various regions, the seriousness of the issues involved in "paying for exports" cannot be ignored. The retrospective review by the tax bureau may take several years, and paying taxes is only the tip of the iceberg. Once it involves crimes such as defrauding export tax refunds, issuing false value-added tax special invoices, illegal business operations, tax evasion, or providing false certification documents, the consequences will be extremely serious.

It is understood that many sellers have claimed to have received tax payment notices.

I've been paying too much lately. My friend has been paying for it for a few years, and these days he's been too honest to leave

Our company's business has already collapsed, and the boss dare not do it. We are also happy to be idle, and the boss is not coming to the company now

No wonder we've been checking the accounts for the past year or two since last week. Fortunately, the data is clear, but it's too trivial

Faced with an increasing number of companies having to pay taxes and fines due to the issue of "paying for exports", this phenomenon has caused deep concern among sellers who also adopt this method. They are worried that they may become the next target of regulatory agencies, facing similar financial burdens and legal consequences.

This uneasy sentiment is gradually spreading within the industry, prompting some sellers to re-examine their business operations and consider taking corresponding measures to ensure the legality and compliance of their business.

Nowadays, with the strict inspection by the tax bureau, various urgent notices regarding customs declaration have also come one after another.

Recently, a customs broker in Shenzhen has issued consecutive notices that they will no longer accept payment for customs clearance services. At the same time, it also reminds companies to transition to formal customs clearance as soon as possible. The impact of paying for customs clearance cannot be ignored. With the continuous improvement of the Golden Tax Phase IV, cross-border e-commerce big data inspection for paying for exports requires self payment of taxes. In addition to investigating the customs clearance agency, the freight forwarder and consignor will ultimately be traced. The consignor found requires payment of 13% value-added tax and 25% corporate income tax based on the trade volume.



And the same warning was also revealed in another related notice. The notification shows:

Recently, strict inspections have been carried out on steel products and payment orders. The customs risk control department has increased the inspection rate for steel products. Customers are required to truthfully declare and pay taxes, as the customs system is now connected to the tax system. Once the inspection is completed, there may be inconsistencies in the information between the two parties (the tax system does not have a record of paying taxes on this ticket, but the customs system declares its export). The consequences are very serious, including fines for withholding goods and paying taxes, as well as providing various supporting documents (there are many types of documents, and it is particularly difficult for normal customs clearance enterprises to prepare them).

So please make sure not to participate in any behavior that does not comply with regulations, such as paying the bill, concealing information, omitting information, etc., and abide by company rules and regulations while also protecting yourself. Everyone must remember this! At present, the steel coils and steel products that have been inspected, as well as the documents requested by customs, are provided for your reference:

1. Manufacturer's quality inspection form;

2. Purchase invoice and bank statement information of the payment made for the purchase of the batch of goods;

3. Export invoice supervised by tax authorities (with product name, quantity, and amount consistent with the customs declaration);

4. Export packing list/equipment handover form;

5. Transport vehicle number and driver's contact phone number;

6. The contact names and phone numbers of the real shipper, inspection agent, and freight forwarder;

7. Settlement of transportation costs.

Additionally, please pay special attention to Article 6. If any issues are identified later, the enterprise, customs broker, and freight forwarder will all be investigated.

It is understood that currently, the focus of tax verification is on products with zero tax rebate rate. According to tax laws, products with zero export tax rebate rates are considered as domestic sales and are required to pay the corresponding taxes according to regulations, which is the difference between the output tax and the input tax. Especially for steel products, their inspection rate has significantly increased. Previously, due to the discovery of a large number of steel products being illegally exported and many goods being detained at ports, the supervision of steel was particularly strict.

For many small and medium-sized sellers, "pay to export" provides great convenience, especially for companies that do not have import and export operation rights, have small value of goods, low tax refund rates, or cannot obtain invoices during procurement, thus unable to declare and refund taxes through normal channels. It can indeed reduce many cumbersome procedures.

However, even for many small and micro enterprises that choose the "pay to export" method, the original intention is to save costs and simplify the export process in order to achieve smooth exports. However, even if the goods themselves have no problems and can be cleared smoothly, it does not mean that the operation is risk-free.

Because some freight forwarders engaged in "pay to export" business may have multiple export companies at the same time, these nominal export enterprises are often shell companies registered for only a few months, and their qualifications and documents are difficult to withstand scrutiny. Once the trading volume expands, the banking system will activate an automatic regulatory mechanism. Due to the direct connection between the shippers and these transactions, they are likely to be included in the scope of suspicion review, which will have a significant impact on the company's cash flow - possibly leading to bank account freezing, Hong Kong bank account closure, and in the most serious cases, even suspected of money laundering.

In addition, the behavior of "paying for exports" may lead some people to use the export data obtained through the payment method to apply for export tax rebates, financial subsidies, or handle foreign exchange affairs, causing incalculable losses to the country's tax revenue.

At present, both customs and local regulatory agencies are strengthening their supervision of the behavior of "paying for exports". Therefore, sellers should no longer take such risky actions and should quickly achieve compliance with the customs declaration process. Especially with the launch of the "Golden Tax Phase IV" system, tax supervision will become more stringent through big data analysis. If sellers want their business to develop steadily in the long term, they must comply with relevant laws and regulations and conduct their business in a legal and compliant manner.