What core compliance procedures and qualification filings are required for Hainan transit trade?

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I am a trader specializing in transit trade of Southeast Asian building materials. I recently plan to transit a batch of Vietnamese marble to the EU via Hainan Yangpu Port. I have been using Hong Kong for transit before, and this time I want to try the policy dividends of Hainan, but I have no experience at all.

Last week I saw a peer's Moments late at night, saying that a batch of their ceramic tiles was detained at Yangpu Port for 7 days and fined more than CNY 20,000 just because they missed a transit-related filing. I am very anxious now, afraid of making mistakes.

I would like to ask what specific matters need to be handled from qualification filing, customs clearance process, tax declaration to risk prevention and control? Are there any easily overlooked details that need to be handled in advance?

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Daniel Xu
Daniel XuYears of service:10Customer Rating:5.0

Director of Import & Export OperationsStart a Chat

First of all,you need to complete Transit Trade Qualification Filing,which is the core pre-link: you need to submit the transit trade operation qualification application form,copy of business license,and transit trade performance certificate for the past 1 year (provide business feasibility statement if there is no performance) to Hainan Yangpu Port Customs 10 working days in advance. After passing the review,you will get the "Transit Trade Compliance Filing Notice",which is the core voucher for subsequent customs clearance. Missing this document will directly trigger a port detention warning.

Three types of key matters need to be handled at core process nodes: First,3 days before the cargo arrives at the port,submit the "Advance Declaration Form for Transit Trade Goods" to the customs,and upload the title document (copy of ocean bill of lading),cargo packing list and certificate of origin at the same time (it needs to be marked with "transit goods" to avoid being judged as direct import),Second,after the cargo arrives at the port,cooperate with the customs to complete the inspection and filing of transit goods,submit the seal verification record form on site,and ensure that the goods are not unpacked within Hainan territory,Third,24 hours before departure,handle the "Transit Goods Departure Release Notice",and complete Foreign Exchange Receipt and Payment Filing simultaneously at this link to ensure that the capital flow,ownership flow and document flow are consistent.

Emergency filing for abnormal situations needs to be handled in advance: if document discrepancy is found after the cargo arrives at the port,submit the "Transit Trade Document Correction Application" within 24 hours,and apply for extension of the temporary free storage period at the same time to avoid high detention fees,if you encounter customs valuation query,prepare supporting documents such as upstream and downstream contracts of transit trade,freight forwarding agreement in advance,and handle the price dispute review application.

To complete the final compliance implementation,you need to complete the transit trade data verification: within 15 days after the cargo departs,submit the "Transit Trade Goods Verification Form" to the customs,and submit the transit trade tax exemption filing to the tax department at the same time,to ensure compliance with the tax exemption policy for Hainan off-island transit trade and avoid unnecessary tax costs.

Reference: How Hangzhou Enterprises Avoid Tariff Barriers and Supply Chain Risks via Third-Party Entrepot Trade
Victor Sun
Victor SunYears of service:5Customer Rating:5.0

Trade Risk Control ManagerStart a Chat

When declaring transit trade, you need to handle the "dual declaration" procedures for transit goods: First, for the inbound declaration of transit goods upon arrival, you need to clearly check "transit trade (0130)" in the "trade mode" column of the declaration form, and mark the final destination port and consignee information in the remark column; Second, for the outbound declaration of transit goods upon departure, you need to submit a copy of the inbound declaration form at the same time to ensure that the cargo information of the two declarations is completely consistent.

If the dual declaration is not handled, it will be judged as general import by the customs, you need to pay import duties and value-added tax retrospectively, and it may also trigger subsequent customs audits. In addition, you need to handle the customs "customs clearance integration" filing in advance to ensure real-time synchronization of declaration data between Hainan port and the outbound port, so as to avoid departure obstruction caused by data delay.

Linda Gao
Linda GaoYears of service:7Customer Rating:5.0

Documentation SupervisorStart a Chat

Key logistics matters to be handled for Hainan transit trade include: First, handle the "free storage period extension filing" for transit goods in advance. The basic free storage period for transit goods at Hainan Yangpu Port is 7 days. If extension is required, submit the "Application for Extension of Free Storage Period for Transit Goods" to the terminal 3 days before arrival, and provide the outbound shipping schedule certificate of the transit goods.

The maximum extension can be 14 days to avoid port detention fees; Second, handle the "order endorsement filing" of the bill of lading. It is necessary to ensure that the endorser of the ocean bill of lading is a business entity that has completed the transit filing, and the endorsement must clearly mark "transit goods, not for sale in the territory" to avoid ownership disputes; Third, handle the "seal locking procedures" for transit goods. After arrival, cooperate with the freight forwarder to complete the verification and re-locking of the customs seal to ensure that the goods are not unpacked without permission during the transit period.

Andy Guo
Andy GuoYears of service:3Customer Rating:5.0

Supply Chain Management ExpertStart a Chat

Tax matters to be handled for Hainan transit trade include: First, handle the "transit trade tax exemption filing" in advance. Before the business is launched, submit the "Transit Trade Tax Exemption Filing Form", transit trade contract, and upstream and downstream customer list to the tax department of Hainan Free Trade Port. After the filing is approved, the transit trade income can enjoy the value-added tax exemption policy; Second, handle the "cross-border related party transaction pricing filing".

If the transit trade involves related companies, submit the related party transaction pricing statement to the tax department before May 31 each year to ensure that the pricing conforms to the arm's length principle and avoid special tax adjustment by the tax department; Third, handle the "non-resident enterprise withholding tax filing". If the transit trade involves overseas commission payment, handle the withholding tax reduction and exemption filing in advance, and eligible entities can enjoy the preferential withholding tax policy of the Free Trade Port.

Grace Wang
Grace WangYears of service:10Customer Rating:5.0

Senior Foreign Trade ConsultantStart a Chat

Foreign exchange receipt and payment compliance matters to be handled for Hainan transit trade include: First, handle the "transit trade foreign exchange receipt and payment quota filing" in advance. Submit the "Transit Trade Operation Qualification Filing Notice" and transit trade contract to the bank, and the bank will verify the foreign exchange receipt and payment quota according to the business scale. Cross-border foreign exchange receipt and payment cannot be handled without filing; Second, handle the "transit trade marking" of SWIFT messages.

When sending foreign exchange receipt and payment messages, fill in "121010 (transit trade receipts and payments)" in the "transaction code" column of the message, and mark "Hainan Free Trade Port Transit Trade" in the postscript column to ensure that the foreign exchange receipt and payment data are identified as compliant transit trade by the foreign exchange administration; Third, handle the "offshore account fund transfer filing". If you use an offshore account for foreign exchange receipt and payment, submit the detailed statement of transit trade funds in the offshore account to the foreign exchange administration every month to avoid being judged as abnormal capital flow.

Eric Zhou
Eric ZhouYears of service:6Customer Rating:5.0

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

Legal related matters to be handled for Hainan transit trade include: First, handle the "notarization and filing of ownership transfer agreement". Submit the ownership transfer agreement of the transit trade to the notary office of Hainan Free Trade Port for notarization.

The notarized agreement can be used as the core voucher for customs and bank review to avoid ownership disputes; Second, handle the "force majeure clause filing". Clarify the scope of force majeure in the transit trade contract, and submit the contract to the legal service center of the Free Trade Port for filing.

If cargo delay is caused by force majeure such as port congestion and policy adjustment, the liability for breach of contract can be exempted according to the filed contract terms; Third, handle the "customs protection filing of intellectual property rights". If the transit goods involve trademarks and patents, handle the intellectual property rights filing with the customs in advance to avoid the goods being detained due to suspected infringement.

Evelyn Li
Evelyn LiYears of service:3Customer Rating:5.0

Cross-border Compliance SupervisorStart a Chat

On-site inspection matters to be handled for Hainan transit trade include: First, handle the "transit goods inspection appointment filing" in advance. Submit the "Transit Goods Inspection Appointment Application" to the customs 24 hours before the cargo arrives at the port, and provide the MSDS report of the goods (if it is dangerous goods).

The customs will give priority to arranging the inspection of transit goods to shorten the inspection time; Second, handle the "seal authenticity identification filing". After the cargo arrives at the port, cooperate with the customs to complete the authenticity identification of the seal, and enter the identification result into the customs system.

If the seal is tampered with, handle the "cargo abnormality filing" immediately to avoid being judged as illegal transit; Third, handle the "inspection result confirmation filing". After the inspection is completed, sign the "Transit Goods Inspection Result Confirmation" on site, and keep a copy as the voucher for subsequent verification.

Kevin Lin
Kevin LinYears of service:4Customer Rating:5.0

Trade Solutions ManagerStart a Chat

Tax refund related matters to be handled for Hainan transit trade include: First, handle the "separate filing of transit trade and export tax refund business". Submit the "Transit Trade Business List" to the tax department to clearly distinguish between transit trade and general export business, so as to avoid transit trade income being mistakenly included in the scope of export tax refund declaration, which will trigger tax inquiry; Second, handle the "transit trade document filing".

Sort and file documents such as transit trade contracts, bills of lading, packing lists, foreign exchange receipt and payment vouchers, and submit the filing list to the tax department, with a retention period of 5 years; Third, handle the "transit trade capital return verification filing". Submit the detailed capital flow statement of the transit trade to the tax department to prove that the capital has not returned domestically, so as to avoid being judged as false transit trade.

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