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What customs supervision calibers and data standards shall be followed for bonded zone entrepot trade statistics?
or complex compliance issues.
clearance and fund security.
I am the document supervisor of a foreign trade company in Shanghai mainly engaged in entrepot trade of electronic components from Southeast Asia, and I have been extremely worried recently. Last month, we had 3 batches of electronic components transshipped in Yangshan Bonded Zone. When counting the cargo value, the finance department required that logistics fees and advanced storage fees should be included, while customs declaration required only the FOB value of goods to be counted.
The requirements of the two parties are completely conflicting, which also led to the stagnation of our foreign exchange receipt and payment compliance verification last month. Worse still, one batch of the goods was entrusted to a third party for agent transshipment, and I have no idea how to distinguish the statistical caliber of agency fees. Now the customs is urging for statistical reports, and the finance department is pressing for account balancing. I am afraid that mistakes will lead to compliance inspection, so I would like to ask how to carry out statistics for bonded zone entrepot trade, and what are the caliber differences and declaration requirements in different scenarios?
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
First of all，dual-caliber verification of pre-documentation shall be completed. The customs statistical caliber takes the FOB value of goods as the core，excluding additional costs such as logistics，storage and customs declaration fees. The value marked on the manifest and bill of lading shall be checked in advance to ensure consistency with the actual transaction contract of the goods，for financial and tax statistics，the actual costs corresponding to foreign exchange receipt and payment shall be distinguished，documents such as advance payment agreements and foreign exchange payment vouchers shall be verified，and the nature and flow of non-cargo value expenses shall be marked.
Core nodes shall ensure "consistency between documents and goods，data from the same source": when entrepot goods enter the zone，"entrepot trade filing" shall be declared on the international trade "Single Window"，and the statistical data shall fully match the cargo value on the manifest and bill of lading，when declaring exit from the zone，the statistical ledger shall be updated synchronously to ensure that the entry filing，exit declaration and foreign exchange receipt and payment data form a closed loop，it is strictly prohibited to adjust cargo value or split statistical items at will.
Plans shall be formulated in advance for abnormal scenarios: if third-party advanced storage and logistics costs are involved，a separate cost explanation letter shall be issued，clearly noted in the statistical report，and submitted to the customs and financial and tax departments for filing synchronously，if there is a difference in statistical data，an application for modifying the filing data shall be submitted within 3 working days to avoid triggering customs compliance verification due to overdue.
The final compliance implementation requires the establishment of an internal double-review mechanism. The enterprise's statistical ledger shall be cross-compared with the data of the customs "Bonded Supervision System" every month，and all documents shall be retained for at least 5 years to ensure that the statistical data are traceable and verifiable，and completely avoid compliance risks caused by caliber conflicts.
Daniel XuYears of service：10Customer Rating：5.0
Director of Import & Export OperationsStart a Chat
The core of bonded zone entrepot trade statistics is to strictly follow the Customs Statistical Measures for Bonded Supervision Zones. When declaring, the statistical calibers of "entry into the zone from domestic" and "entry into the zone from overseas" shall be distinguished: for entrepot goods entering the zone from overseas, the statistical cargo value is subject to the commercial invoice issued by the overseas seller, while for entrepot goods entering the zone from domestic, the statistical cargo value is subject to the value on the VAT invoice of the domestic seller.
It should be noted that the customs statistical system will automatically compare the consistency of manifest, bill of lading and declaration data. If the cargo value deviation exceeds 5%, the system will trigger manual document review, and even lead to customs inspection. It is recommended to upload all documents to the customs pre-audit system one day before declaration, and confirm the data matching before formal declaration, so as to avoid document deletion and re-declaration or port detention caused by statistical errors.
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
From the perspective of logistics links, bonded zone entrepot trade statistics need to track the cargo right transfer node and logistics status simultaneously: when goods enter the zone, the status of "to be shipped out after transshipment" shall be marked in the logistics system, the statistical cargo value only includes the value of the goods themselves, and logistics costs such as storage, loading and unloading, transportation after entering the zone shall be counted separately and shall not be included in the entrepot cargo value. If transit distribution is involved, statistics shall be split according to the actual exit cargo value of each batch to avoid data deviation caused by whole batch statistics.
In addition, it is necessary to ensure that the cargo right transfer information on the bill of lading endorsement is consistent with the statistical data. If the cargo right is transferred to a third party, the information of the transferee shall be noted in the statistical report to avoid port detention risks caused by inconsistency between cargo right and statistical subject.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
From the tax perspective, bonded zone entrepot trade statistics need to distinguish between taxable and non-taxable items: entrepot trade itself is a tax-free item, the statistical cargo value only includes the FOB value of the goods, and additional costs such as logistics and customs declaration shall not be included, otherwise the taxable base will be falsely high, leading to tax inspection.
If cross-border related transactions are involved, the statistical cargo value shall comply with the arm's length principle to avoid tax adjustment caused by related party pricing deviating from market price. It is recommended to establish a tax statistics ledger, separately account for the cargo value, expenses, foreign exchange receipt and payment data of entrepot goods, and compare with customs statistical data every month to ensure that tax declaration is consistent with customs statistical caliber, and retain related transaction pricing explanations for tax authority verification.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
Bonded zone entrepot trade statistics shall meet the compliance requirements of foreign exchange receipt and payment simultaneously: the statistical data shall be consistent with the amount of SWIFT messages or CIPS payment vouchers. If there are advanced expenses, "entrepot trade advanced expenses" shall be noted in the foreign exchange payment voucher and listed separately in the statistical report, and shall not be mixed with the cargo value.
It should be noted that the State Administration of Foreign Exchange will compare the consistency of statistical data and foreign exchange receipt and payment data through the "Cross-border Capital Flow Monitoring System". If the deviation exceeds 10%, it will trigger foreign exchange compliance verification, and even suspend the enterprise's foreign exchange receipt and payment authority. It is recommended to report the statistical data to the pre-audit system of the State Administration of Foreign Exchange in advance before foreign exchange receipt and payment, and go through the formalities after confirming compliance.
Evelyn LiYears of service：3Customer Rating：5.0
Cross-border Compliance SupervisorStart a Chat
The statistical data of bonded zone entrepot trade shall be consistent with the agreement of the trade contract: the cargo value of entrepot goods and expense sharing method shall be clearly specified in the contract, and the cargo value and expenses shall be split strictly in accordance with the contract agreement during statistics, so as to avoid trade disputes caused by inconsistency between statistical data and the contract.
If a third party is involved in agent transshipment, the subject of statistical responsibility shall be clearly specified in the agency agreement to avoid legal risks caused by inconsistent statistical calibers between the agent and the principal. In addition, all trade contracts, agency agreements and statistical reports shall be retained for at least 10 years to prepare for potential trade arbitration or compliance investigation.
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
In the on-site inspection link, the statistical data of bonded zone entrepot trade shall be consistent with the quantity and value of actual goods: during inspection, the customs will check the brand, model and quantity of the goods against the statistical data. If the actual goods are inconsistent with the statistical data, warehouse detention inspection will be triggered, and even the transshipment business will be suspended.
It is recommended to take inventory of the goods in advance before entering the zone, and make a detailed cargo list to ensure that the statistical data is consistent with the actual goods; if there is cargo loss, the reason and quantity of the loss shall be noted in the statistical report, and a loss certificate recognized by the customs shall be submitted to avoid inspection risks caused by statistical data deviation due to loss.
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
From the perspective of export tax rebate audit, the statistical data of bonded zone entrepot trade shall be strictly distinguished from the tax rebate declaration data: entrepot trade is not within the scope of export tax rebate, and the item of "entrepot trade" shall be marked separately during statistics, and shall not be mixed with general trade export data, otherwise the tax rebate declaration data will be wrong, leading to tax correspondence adjustment. It is recommended to establish a classified statistical ledger, separately account for the data of entrepot trade, general trade and processing trade, and conduct cross comparison every month to ensure that the boundary between tax rebate declaration data and statistical data is clear, and retain all documents of entrepot trade for export tax rebate audit verification.