9810模式海外仓备案取消、离境即退税新政解析

Core Viewpoint - The new policy completely abolishes the registration requirement for cross-border e-commerce export overseas warehouse business models, allowing companies to directly engage in overseas warehouse operations with only basic registrations required [2][3]. Policy Basis and Effective Date - The policy is based on the General Administration of Customs Announcement No. 167 of 2024 and will take effect on December 15, 2024 [2]. Impact Analysis - Supply Chain Flexibility: Companies can freely choose and switch third-party overseas warehouse resources globally, enabling a plug-and-play supply chain layout [3]. - Decision-Making Efficiency: The cancellation of the registration process reduces preparation time from weeks to zero, allowing companies to quickly respond to market opportunities [3]. - Reduction of Transaction Costs: The reform cuts down on administrative costs in terms of time, manpower, and communication, enabling companies to focus more on core business development [3]. Transformation of Overseas Warehouse Operations - The cancellation of registration transforms overseas warehouses from fixed assets requiring approval into on-demand, scalable cloud services, facilitating global, agile, and intelligent supply chain management [4]. Tax Refund Process - Sales Achieved at Declaration: Companies can directly process tax refunds according to existing export tax refund regulations [6]. - Sales Not Achieved at Declaration: Companies can apply for pre-tax refunds under the "departure tax refund" model and must accurately fill in the "overseas warehouse pre-refund" identifier in the declaration details [7]. - Core Tax Policy: The policy implements "departure tax refund, sales accounting afterward," allowing companies to apply for tax refunds immediately after goods leave the country [8]. Cash Flow Improvement - The new policy significantly shortens the tax refund cycle from several months to weeks after departure, alleviating the financial burden on companies [9]. - For example, a company exporting goods worth 10 million yuan with a 13% tax refund rate would previously wait about six months for a 1.3 million yuan refund. Under the new policy, the refund process can start immediately after departure, enhancing capital efficiency by over 30% [10]. Regulatory Framework - The adjustment is part of a broader regulatory framework involving four key systems that work together to create a "trust-based supervision" model [13]. - Customs Side: Simplification of entry requirements, cancellation of overseas warehouse registration, and expansion of pilot programs for post-shipment inspections [14]. - Tax Side: Implementation of the "departure tax refund" model and clear guidelines for "overseas warehouse pre-refund" [14]. - Information Side: Regularized strong reporting of tax-related information to support accurate data verification by tax authorities [14]. Compliance and Legal Responsibilities - Companies must retain sales evidence within 15 days after sales are realized, ensuring the documentation is genuine and complete [16]. - Failure to comply with documentation requirements may result in tax recovery and potential penalties, with tax authorities initiating investigations for suspected tax fraud [16].