由 caicai8478 Introduction
In international trade, double customs clearance has become a common practice for many companies to optimize logistics costs and efficiency. However, behind this operation is a little-known “gray trap” – the problem of inconsistent declarations. When the declaration information of enterprises in different customs areas is different, they may face severe penalties from customs, or even receive staggeringly high fines.
Operation mode of double customs clearance
Double customs clearance usually refers to the operation of enterprises declaring the same batch of goods in two different customs areas (such as the port of the importing country and the inland customs). Common forms include:
Port customs clearance + inland customs transfer
Bonded customs clearance + domestic market customs clearance
The “1210” and “9610” models of cross-border e-commerce are in parallel
The original intention of this operation is to reasonably utilize the policy advantages of different customs areas, reduce tax burdens or improve customs clearance efficiency, but improper operation can easily lead to the risk of inconsistent declarations.
The “gray trap” of inconsistent declaration
Inconsistent declaration is mainly manifested in the following aspects:
Commodity classification differences: the same commodity is declared using different HS codes in different customs areas
Price differences: the declared prices are significantly different in different customs areas
Quantity differences: the total quantity is inconsistently declared in each link
Origin differences: the same commodity is declared with different origins
Regulatory certificate differences: the required certificates are inconsistently declared in different customs areas
These differences may be due to operational errors, or they may be deliberately done by enterprises to achieve tax avoidance purposes. Regardless of the original intention, once discovered by customs, it may be regarded as a violation.
Legal basis for sky-high fines
According to the Customs Law and related regulations, inconsistent declarations may violate the following provisions:
False declaration: a fine of 5%-30% of the value of the goods
False declaration: a fine of 30%-100% of the value of the goods, and criminal liability will be pursued if it constitutes a crime
Smuggling: confiscation of goods and fines, and criminal liability will be pursued in serious cases
Typical cases show that a company was fined 80% of the value of the goods for declaring different prices for the same batch of goods in double customs clearance, and the amount was as high as tens of millions of yuan.
Risk prevention suggestions
To avoid falling into the “grey trap”, enterprises should take the following measures:
Establish a unified declaration standard: use consistent HS codes, prices and origin information throughout the process
Improve the internal audit mechanism: set up a special position to check the declaration documents at each stage
Take advantage of AEO certification: gain more trust through customs advanced certification enterprise qualification
Regular compliance training: improve the professional level and compliance awareness of customs personnel
Introduce professional customs clearance consultants: use external professional forces to avoid risks
Conclusion
Double customs clearance is like a double-edged sword. Reasonable use can bring benefits to enterprises, but improper operation may lead to serious consequences. Today, when customs supervision is becoming increasingly intelligent, enterprises should pay more attention to declaration consistency to avoid losing the big picture due to small gains and falling into the “grey trap” and facing the risk of sky-high fines. Compliance operation is the lasting way for international trade.