Can Import Agency Fees Be Included in Goods Procurement Costs? What Compliance Requirements Apply to Accounting Treatment?

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I am the finance supervisor of a precision machinery manufacturer in Shanghai. Last week, we imported a batch of German-made core components for machine tools through Zhongshen as our import agent. Now it is time to do the monthly accounts, and I am stuck: can the 12,000 yuan import agency fee incurred this time be included in the procurement cost of these components?

I heard from peers that if the classification is wrong, not only will there be problems with input tax deduction during tax declaration, but we may also get an early warning and audit from the tax authority. But if it is classified as period expense, it will push up the current period cost and affect profits.

The leader is still urging me to finalize the accounting plan as soon as possible. I am very anxious now, afraid of stepping into the pit of fiscal and tax compliance by accident. I would like to ask about the accounting rules for agency fees under different trade clauses, the compliance requirements for accounting treatment, and whether it will affect the subsequent final settlement?

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Expert Q&A

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

Documentation SupervisorStart a Chat

First of all,it should be clear that not all import agency fees can be included in goods procurement costs. A common industry misunderstanding is that all agency fees are uniformly included in costs or expenses regardless of the type of agency service and trade clauses. This operation is very likely to trigger tax early warnings,leading to failure of input tax deduction or adjustment in final settlement.

If the import agency fee is a service fee directly related to the goods incurred to facilitate the procurement of goods (such as customs declaration agency,port miscellaneous fee agency,etc.),and the corresponding trade clause is FOB or EXW,it can be included in the goods procurement cost,if it is a fee for separate services such as agency customs clearance,logistics scheduling that are not directly related to goods procurement,it shall be included in period expenses.

Two core conditions shall be met in operation: first,retain compliant agency service invoices,which clearly indicate the service content and corresponding imported goods,second,associate and file the agency fee with the procurement contract of imported goods,bill of lading and other vouchers.

Calculated from the perspective of income,after eligible agency fees are included in costs,they can be used as the base for input tax deduction. Compared with being included in period expenses,it can reduce the enterprise's VAT tax burden by about 13% (according to the tax rate for general taxpayers),and reduce the risk of tax adjustment during final settlement,which is more conducive for enterprises to accurately calculate inventory costs.

Reference: Full Analysis of Import and Export Freight Forwarding Fee Structure: Where Does Every Cent of Your Expense Go?
Victor Sun
Victor SunYears of service:5Customer Rating:5.0

Trade Risk Control ManagerStart a Chat

From the perspective of customs valuation, whether the import agency fee can be included in the dutiable value of goods is a precondition for it to be included in procurement costs. If the agency service is a must for the buyer to import goods and the fee is not included in the paid or payable price of the goods, the customs will include it in the dutiable value, and the corresponding agency fee can be included in the goods procurement cost simultaneously; if the agency fee is for services independently entrusted by the buyer to a third party that are not mandatory related to the import of goods (such as separate market research, business negotiation agency, etc.), it will not be included in the dutiable value in customs valuation, and such agency fee shall be included in period expenses.

Enterprises should note that the customs will require the provision of agency contracts, payment vouchers and other materials during valuation. If the direct correlation between the agency fee and the import of goods cannot be proved, they may be required to adjust the dutiable value, resulting in tax repayment and late fees.

Michael Zhang
Michael ZhangYears of service:6Customer Rating:5.0

Customs Declaration & Compliance ExpertStart a Chat

From the perspective of international logistics chain, the classification of import agency fees shall be judged in combination with the binding relationship of logistics services. If the agency fee is a "one-stop agency service" fee (including booking, customs declaration, port miscellaneous fees, etc.) under CIF and CIP trade clauses, it can be included in the goods procurement cost because it is a necessary expenditure before the goods arrive at the import entry point in China and are unloaded; if the agency fee is a separate logistics value-added service fee incurred after the goods arrive at the port (such as domestic distribution agency, warehouse management agency, etc.), it belongs to the subsequent expenditure after the import of goods and shall be included in sales expenses or administrative expenses.

In addition, if the agency service involves abnormal expenditures such as container detention fees and port demurrage charges, such fees are additional costs caused by operational errors, and shall be included in period expenses regardless of the trade clause, and cannot be included in goods costs.

Jason Wu
Jason WuYears of service:10Customer Rating:5.0

International Logistics & Supply Chain ManagerStart a Chat

From the perspective of tax deduction, the input tax corresponding to the import agency fee included in the goods procurement cost can be deducted according to regulations, but three conditions shall be met: first, obtain a legal and valid special VAT invoice, and the remark column of the invoice shall indicate the customs declaration number of the imported goods; second, the agency fee is directly related to the production and operation of the imported goods, and the input of agency fee corresponding to goods used for simple tax calculation projects and tax-exempt projects cannot be deducted; third, the payment time of the agency fee shall match the entry time of the goods.

If the agency fee is paid in advance but the goods have not been put into storage, it shall be included in prepaid accounts first, and then transferred to procurement costs after the goods are put into storage. Enterprises should note that if the non-deductible input tax of agency fees is included in the cost, tax adjustment shall be carried out during final settlement, otherwise it may trigger tax audit risks.

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

Cross-border Compliance SupervisorStart a Chat

From the perspective of cross-border foreign exchange receipt and payment compliance, the accounting classification of import agency fees will affect the declaration logic of foreign exchange receipt and payment. If the agency fee is included in the goods procurement cost, it shall be included in the total amount of foreign exchange payment for goods import, and marked as "trade in goods - general goods import" when declaring the balance of payments; if the agency fee is included in period expenses, it shall be declared separately for service trade foreign exchange payment and marked as "trade in services - other business services".

Enterprises shall strictly distinguish between the two declaration calibers. If the declaration is confused, they may be listed as the focus of attention by the State Administration of Foreign Exchange, which will affect the subsequent approval of foreign exchange payment quota and even lead to compliance penalties. In addition, if the agency fee is paid to overseas related parties, it is necessary to ensure that the pricing conforms to the arm's length principle to avoid anti-avoidance investigation caused by unreasonable related party transaction pricing.

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

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

From the perspective of trade contract compliance, the classification of import agency fees shall be based on the contract agreement. If the import agency contract clearly stipulates that the agency fee is a supporting fee for goods procurement, borne by the buyer and included in the total price of goods, such agency fee can be included in the goods procurement cost; if the contract stipulates that the agency fee is an agency service fee paid separately by the buyer and separated from the goods price, it shall be included in period expenses.

Enterprises should note that if the contract does not clarify the classification of the agency fee, it is easy to cause disputes in subsequent accounting and tax declaration. It is recommended to clarify the nature, payment method and accounting classification clauses of the agency fee when signing the agency contract, to avoid fiscal and tax risks caused by vague contract clauses. In addition, if the agency fee involves a third-party service provider, it is necessary to ensure that the rights and obligations of the agency contract are clear, so as to avoid affecting the goods import process due to service disputes.

Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

From the perspective of on-site customs inspection, the correlation between import agency fees and goods costs shall be judged in combination with the service content in the inspection link. If the agency fee includes the service fee for assisting on-site inspection (such as container unpacking agency, inspection submission agency, etc.), and the service is a necessary link for the import clearance of goods, such agency fee can be included in the goods procurement cost; if the agency fee is a non-compliant fee paid to avoid inspection risks, it can not be included in the goods cost, but also may lead to administrative penalties from the customs.

Enterprises should note that legal inspection assistance agency fees need to obtain formal invoices, and the service content shall be clearly marked in the agency contract. If compliant vouchers cannot be provided, such fees shall be included in period expenses and cannot be deducted for tax purposes.

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

Trade Solutions ManagerStart a Chat

From the perspective of supply chain cost actuarial calculation, whether the import agency fee is included in goods cost or expense will affect the inventory accounting and cost control of enterprises. If eligible agency fees are included in the goods procurement cost, the actual cost of unit goods can be calculated more accurately, providing accurate data support for production pricing and inventory management; if they are included in period expenses, the unit goods cost accounting will be low, which may affect the enterprise's pricing strategy and profit calculation.

Enterprises can establish a cost actuarial model to distinguish different types of agency fees, include agency fees directly related to goods into inventory costs, and non-directly related ones into period expenses, so as to realize accurate control of supply chain costs and improve the profitability and market competitiveness of enterprises.

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