Introduction #
The 9710 model, officially referred to as the “Cross-Border E-Commerce B2B Direct Export” model, is a regulatory mechanism introduced by China Customs in 2020 to facilitate B2B cross-border trade. The pilot program commenced on June 12, 2020, under the General Administration of Customs Announcement No. 75 (2020), and was subsequently rolled out nationwide pursuant to Announcement No. 47 (2021).
By simplifying customs procedures and offering streamlined foreign exchange settlement channels, the 9710 model aims to enhance the efficiency of B2B export operations in the e-commerce sector. It also permits licensed agents to conduct export declarations and handle foreign exchange settlement on behalf of clients under simplified procedures. This article provides a comprehensive guide to the operational process of B2B direct exports under the 9710 model and identifies the key compliance issues in taxation and foreign exchange.
I. Operational Guidelines for Cross-Border E-Commerce B2B Direct Export #
Cross-border B2B direct exports refer to the sale of goods by Chinese enterprises to foreign businesses or end-buyers via e-commerce platforms. Unlike traditional exports, B2B e-commerce exports involve multiple stages including online transactions, digital payment, warehousing, and logistics. The basic procedural steps are as follows:
1. Product Filing and Export Declaration #
Enterprises must pre-register export products in the customs system to ensure that all product information is complete and compliant. Electronic declarations must include product codes, categories, quantities, origin, and other required data in accordance with customs regulations.
2. Cross-Border Logistics and Customs Clearance #
B2B direct exports may adopt various logistics approaches, including direct customs declaration, export via consolidation warehouses, or bonded warehouse dispatch. Enterprises should select the method that best suits their operational model and engage licensed logistics providers.
For customs clearance, enterprises are required to submit full documentation such as packing lists, commercial invoices, and contracts, ensuring that the documentation is fully consistent with the customs declaration data.
3. Overseas Payments and Foreign Exchange Settlement #
Payments are typically made through platform-integrated payment systems or third-party payment processors. Enterprises must ensure that the amount received corresponds with the declared export order, thereby enabling compliant foreign exchange settlement with authorized banks.
4. Customs Supervision and VAT Rebate #
Customs supervision is a critical component of the 9710 model. Where eligible, enterprises may apply for export VAT refunds, provided they meet the applicable regulatory conditions.
II. Tax Compliance Issues in B2B Direct Exports #
Tax compliance under the 9710 model involves issues related to value-added tax (VAT), corporate income tax (CIT), and electronic invoicing. A robust tax compliance system is essential to mitigate tax risks in cross-border e-commerce.
1. Export VAT Refund Policy #
According to China’s VAT export policy, qualifying exported goods under the 9710 model may be eligible for VAT refunds. Key conditions include:
- Clear title to goods and control of the supply chain;
- Proper VAT invoices for input purchases;
- Adequate documentation for export transactions.
To apply for a VAT refund, enterprises must submit export declaration forms, special VAT invoices, and other supporting documentation to establish the authenticity and legality of the export transaction.
2. Corporate Income Tax (CIT) #
Revenue derived from 9710 B2B direct exports must be included in the taxable income base for corporate income tax purposes. Enterprises must declare sales revenue in a timely manner and fulfill their CIT filing obligations.
If the enterprise engages in transfer pricing or other tax planning arrangements, such transactions must comply with the relevant rules of the State Taxation Administration. Export pricing must be reasonable to avoid tax risks associated with inappropriate transfer pricing.
3. E-Invoicing and Tax Filing #
For export transactions, e-commerce enterprises must complete electronic filing of VAT invoices within the tax administration system. Invoice content must be complete, accurate, and consistent with export declaration data to facilitate tax exemption or refund procedures. Errors in invoicing (e.g., missing or incorrect entries) may delay or disqualify tax refunds.
III. Foreign Exchange Compliance in B2B Direct Exports #
Foreign exchange compliance is a key aspect of the 9710 model, particularly in relation to international payment processing and RMB conversion.
1. Foreign Exchange Settlement #
Cross-border e-commerce enterprises may collect payments either via platform accounts or by using overseas bank accounts. In accordance with the Notice of the State Administration of Foreign Exchange on Further Optimizing the Administration of Foreign Exchange for Trade [2024] No. 11, small and micro e-commerce enterprises may settle foreign exchange for trade in goods based on electronic transaction data without having to register in the enterprise foreign exchange receipt and payment directory.
To complete foreign exchange settlement, enterprises must provide supporting documentation including export customs declarations, invoices, and contracts. All records must be internally consistent.
2. Compliance in the Use of Third-Party Payment Platforms #
Many e-commerce enterprises rely on third-party payment platforms to receive funds, especially in direct B2B scenarios. However, different platforms are subject to varying degrees of foreign exchange regulation. Enterprises must ensure that payment processing complies with SAFE policies, and must avoid using unauthorized or non-compliant channels.
In addition, businesses should closely monitor fund transfer policies of payment platforms and maintain clear, auditable records of all financial transactions to facilitate inspections by the foreign exchange or tax authorities.
Conclusion #
China’s cross-border e-commerce B2B export sector under the 9710 model has shown robust growth amid increasing globalization. However, along with new market opportunities come significant compliance challenges, especially in the areas of taxation and foreign exchange regulation.
Enterprises must remain vigilant in observing all applicable laws and regulations, and should establish sound internal compliance systems. Regular communication with the tax authorities and foreign exchange regulators will help reduce legal risks and foster long-term, sustainable development of cross-border B2B e-commerce operations.
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