由 lltx1822 Customs Declaration “Price Inquiry” Response Manual: How to Prepare Transaction Documents and Payment Records?
Introduction
Customs price inquiries are a common clearance risk for import and export enterprises. According to statistics, in 2024, Chinese customs initiated approximately 120,000 price inquiries, involving goods worth over 300 billion yuan, with 35% of tax supplement cases attributed to incomplete transaction documents or unclear payment records. Price inquiries not only delay clearance times (average processing period: 7-15 days) but may also trigger subsequent audits and even affect a company’s credit rating (e.g., AEO certification downgrade).
This article provides a systematic response strategy covering reasons for price inquiries, customs valuation principles, key preparation steps for transaction documents, payment record organization techniques, and case studies, helping enterprises efficiently pass customs reviews.
I. Common Triggers for Customs Price Inquiries
1. Declared Price Deviates from Customs Database
- Automated System Alerts: Customs’ “Dutiable Value Database” compares declared prices with industry averages; deviations exceeding ±10% may trigger inquiries (e.g., declaring IC chips at $5.2/unit vs. the database average of $6.8).
- Related-Party Transactions: Undisclosed affiliations or unadjusted royalties/commissions.
2. Incomplete Documentation Chain
- Missing Key Documents: Discrepancies between Proforma Invoice and Commercial Invoice amounts.
- Unclear Payment Records: Bank statements lacking contract or invoice references.
3. Special Trade Arrangements
- Unreported consignment trades or free repair parts.
- Installment payments without supporting agreements.
Note: Per Customs Valuation Rules (Decree No. 213), customs may reassess values using transaction value, identical/similar goods, deductive value, or other methods.
II. Core Customs Valuation Principles & Legal Boundaries
1. Mandatory “Three Certificates + One Record”
| Document Type | Key Requirements | Legal Basis |
|---|---|---|
| Sales Contract | Must specify FOB/CIF terms | Customs Law Article 55 |
| Commercial Invoice | Seller-stamped original | Valuation Rules Article 8 |
| Payment Proof | SWIFT messages/electronic slips | GAC Announcement 2023-18 |
| Freight/Insurance | Required for CIF valuations | Tariff Regulations Art. 28 |
2. Three Scenarios Justifying Customs Inquiries
- Non-Transparent Pricing: Unreported buyer-borne costs (e.g., tooling/design fees).
- Transaction Authenticity Issues: Payment amounts ≠ contract values.
- Unallocated Special Fees: Technical assistance fees not proportionally included.
Enterprise Rights: Companies may appeal within 15 days of receiving a Price Inquiry Notice.
III. Standardized Process for Transaction Document Preparation
1. Contract Review Essentials
- Price Clause Clarity:
- FOB Terms: Submit separate freight invoices + bills of lading.
- Royalties: Explicit clauses (e.g., “3% patent fee on sales”).
- Related-Party Disclosures:
- Submit Related-Party Declaration for parent-subsidiary trades.
- Provide third-party benchmarking reports (e.g., industry price indices).
2. Invoice Compliance Requirements
- Four-Way Consistency:
Product name, specifications, quantity, and unit price must match the contract exactly. - Discount Breakdown:
- Annual rebates labeled “post-adjustment” with supplementary agreements.
- Free samples marked “no commercial value”.
Case: A company failed to declare a 2% annual discount, resulting in RMB 280,000 in back taxes + penalties.
IV. Payment Record Organization Techniques
1. Bank Statement Annotation Standards
- Required Fields:
Date | Amount | Recipient | Contract/Invoice No. | FX Declaration No. - Sub-Account Management:
- Dedicated accounts per project (e.g., “2024 IC Procurement Account”).
- Use blockchain notarization (e.g., “TradeChain”) to secure records.
2. Handling Special Payment Scenarios
| Scenario | Solution |
|---|---|
| Third-Party Payments | Submit Payment Agency Agreement + proof |
| Cross-Border RMB | Include RCPMIS reference numbers |
| Installments | Provide Installment Agreement + proofs |
Note: Since 2024, customs can verify electronic records via the Cross-Border Payment Data Sharing Platform.
V. Case Studies & Response Strategies
Case 1: Undeclared Freight Costs
- Issue: Declared FOB $100,000, but buyer-paid $5,000 freight was omitted.
- Solution: Supplement B/L + freight invoices + contract clause proof.
Case 2: Transfer Pricing Dispute
- Issue: Parent company sold equipment to subsidiary at $10,000/unit (market rate: $15,000).
- Action: Submit KPMG Transfer Pricing Report + market data.
Case 3: Payment Date Anomalies
- Issue: Bank records showed payment before contract signing.
- Fix: Provide advance payment agreement + seller confirmation.
VI. Future Trend: Digital Document Management
By 2025, customs will fully implement “Smart Valuation Systems”, requiring:
- Structured Data: Contracts/invoices/records in XML/EDI formats.
- API Integration: ERP auto-syncing with customs systems.
- Blockchain Notarization: Use Customs Blockchain for key documents.