Shenzhen Launches Cross-Border E-Commerce “No-Invoice Tax Exemption” Pilot

This comes after the October 2025 tax reform, which has left many cross-border sellers struggling with new compliance challenges, especially regarding “purchase without invoices”. For years, many sellers sourcing products from small and medium-sized domestic manufacturers have often been unable to obtain valid VAT invoices, creating difficulties in meeting tax compliance under the new regulations.

What is “No-Invoice Tax Exemption”?

The “No-Invoice Tax Exemption” allows sellers to export goods without needing purchase invoices while still enjoying VAT exemption.

Recently, several logistics companies in Shenzhen notified their clients, inviting sellers using the “Buy-and-Ship Export” model to register for the pilot program.

For context, “Buy-and-Ship Export” refers to companies without export rights using another company’s export documentation to ship goods under their own name—a practice that has long existed in a regulatory gray area. The pilot program is designed to align with the State Taxation Administration’s 2025 Announcement No. 17, which formalizes this model and supports compliant transformation for cross-border sellers.

How the Pilot Works

• Be a Shenzhen-registered company.
• Logistics companies act as customs agents using 9810 mode.
• Sign an agency authorization agreement and complete export tax exemption registration in the electronic tax system.
• Register for “No-Invoice Exemption” via the Shenzhen Cross-Border E-Commerce Online Service Platform.
• Business, tax, and customs systems automatically compare “three-document data” (invoice, customs declaration, foreign exchange records), granting immediate tax exemption approval once verified.

This process creates a data-closed loop ensuring compliance while exempting eligible goods from VAT and consumption tax.

Benefits for Cross-Border Sellers

1. Significant Tax Savings
   Example: A clothing seller with annual exports of RMB 1,000,000 at a 13% VAT rate could save around RMB 130,000 annually.
2. Streamlined Compliance
   Sellers often face difficulty completing export tax rebate processes without valid purchase invoices. The pilot allows businesses to register shipment information online (product name, quantity, amount, logistics tracking), which automatically links customs, tax, and foreign exchange data, forming a “three-document integrated” compliance loop.

In other words, tax authorities will base exemption eligibility on verified platform and customs data rather than sellers’ invoice completeness. This could fundamentally resolve the long-standing challenges of invoice gaps, export data, and compliance closures for cross-border sellers.

Looking Ahead

Shenzhen’s pilot program represents a practical, implementable solution for sellers who rely on “Buy-and-Ship Export” or struggle with sourcing invoices. According to Shenzhen’s Bureau of Commerce, if successful, the policy could expand nationwide in 2026 across 165 comprehensive pilot zones, benefiting over 100,000 cross-border e-commerce companies.

For Shenzhen-based sellers, now is the time to embrace this opportunity, ensure proper registration, and position themselves for future compliance advantages.

Conclusion

The launch of the “No-Invoice Tax Exemption” pilot is more than just policy news—it’s a real, actionable path for cross-border e-commerce sellers to:

• Legally export goods without purchase invoices
• Reduce tax costs
• Improve financial transparency and operational compliance

While the pilot is still in its early stages and details may evolve, proactive adoption could be a key competitive advantage for cross-border businesses in Shenzhen and beyond.