Recently, multiple authorities including customs, taxation, foreign exchange and public security organs have continuously intensified joint inspection efforts to carry out a concentrated crackdown on the long-standing grey and illegal practice of purchasing and selling export declarations in the foreign trade sector. Relying on the online verification mechanism linking the Golden Tax Phase IV system and tariff data, authorities are conducting full-chain crackdowns on illegal chains such as customs declaration through shell companies, matching purchased declarations with fake invoices, and fabricating trade transactions to fraudulently claim export tax rebates. A string of related cases have been publicly disclosed across numerous regions, marking the official entry of foreign trade supervision into a new era of penetrating oversight.

The so-called purchase and sale of export declarations refer to two practices. "Purchasing declarations" means actual cargo owners who lack import and export qualifications or seek tax evasion pay to acquire the corporate names of shell companies with legitimate import and export rights for customs export declaration purposes. "Selling declarations" occurs when idle shell foreign trade enterprises holding valid qualifications sell their customs declaration entity credentials and blank documents. Under this model, the customs declarant, actual cargo owner, capital flow and physical goods flow are completely disconnected, constituting false customs declarations. This practice readily breeds illegal and criminal acts including issuing fake invoices, foreign exchange settlement through underground banks, and export tax rebate fraud, disrupting foreign trade order over the long term and resulting in massive losses of state tax revenue.

With the upgrading of the supervision system, a host of pivotal policies were rolled out between 2025 and 2026 to curb the room for the declaration purchase-and-sale practice at its source. The General Administration of Customs and the State Taxation Administration jointly issued an announcement mandating the online verification of electronic data for the Certificate of Tax Rebate Recovered / Tax Rebate Unpaid for Export Goods effective January 1, 2026. Tax document data will be directly transmitted to customs to enable two-way cross-checking of customs declaration and tax rebate data. Supporting new tax regulations mandate that authentic information of entrusting parties must be submitted for entrusted export businesses to put an end to the deceptive practice of "ostensible self-operation, actual entrusted agency", thereby closing institutional loopholes that allow shell companies to repeatedly lend their customs declaration titles.

On the law enforcement front, major cases involving declaration purchase, fake invoice matching and tax rebate fraud have been intensively investigated in the Pearl River Delta, Northeast China, Shanxi and other regions. Tax authorities in Shenzhen recently uncovered three enterprises that fabricated fruit export businesses via purchased declarations and matched fake invoices to fraudulently claim 6.31 million yuan in tax rebates. The total recovered tax arrears and fines exceeded 12 million yuan, and the involved enterprises had their export tax rebate eligibility suspended for three years. In gang-related cases across multiple regions, lawbreakers established clusters of shell enterprises to sell customs declaration titles in bulk, paired with fake invoice issuance and capital reflux, with case amounts often reaching tens of millions of yuan. Relevant perpetrators have been held criminally liable in accordance with the law.

Customs inspectors stated that current supervision features data interoperability among customs, taxation, foreign exchange administration and banking authorities. The system can automatically cross-check customs declarations, input VAT invoices, capital transaction records and foreign exchange receipt information to rapidly identify declaration purchase businesses with inconsistent four core flows (goods, capital, invoices and declarations). Once illegal declaration purchase or sale activities are verified, enterprises will face seizure of goods, customs administrative penalties, tax arrears repayment, late fees and multiple-fold fines. Severe tax rebate fraud cases will be directly transferred to public security organs for criminal liability investigation. Freight forwarders and customs brokers that assist in declaration sales or conceal information of actual cargo owners shall bear joint and several legal liabilities as well.

For small and medium-sized foreign trade enterprises, regulatory authorities are guiding market entities to shift to compliant operation models, recommending legitimate export channels including market procurement trade (1039 model), formal foreign trade agency services and self-applied import and export qualifications. Tax and China Council for the Promotion of International Trade authorities remind foreign trade practitioners that there is no "safe operating margin" for export via purchased declarations, and they must not harbour fluke mindsets. Freight forwarders and logistics enterprises are prohibited from accepting customs declaration businesses based on purchased declarations. Enterprises shall promptly revamp their business models for compliance to avert personal legal risks for corporate legal representatives and actual controllers.

Industry insiders noted that the ongoing rectification campaign is not a short-term special operation but an upgrade to regularized supervision. The long-standing grey channels of purchased declarations in the foreign trade sector will face sustained tightening, and the entire foreign trade industry will fully shift toward compliant export models featuring authentic trade transactions, consistent documents and clearly identified business entities.