Calculation of import duty-paid value of multimodal transport goods

Sunny Worldwide LogisticsIt is a logistics company with more than 20 years of transportation experience, specializing in Europe, the United States, Canada, Australia, Southeast Asia and other markets. It is more of a cargo owner than a cargo owner~

The concept of international multimodal transport

The United Nations Convention on International Multimodal Transport of Goods defines international multimodal transport as a place where the multimodal transport operator takes over the goods from the territory of a country in at least two different modes of transport in accordance with the international multimodal transport contract. The transportation of goods to a designated delivery location in another country. The Maritime Law of the People's Republic of China stipulates that domestic multimodal transport must be transported by sea. For international multimodal transport goods, the carrier issues a full transport document, also known as a multimodal transport bill of lading.

With the continuous development of my country's economy, more and more goods enter my country's inland cities through multimodal transport. Inland section transportation has become an important component of multimodal transport, and inland section freight also exists as part of the full freight rate..In reality, there is confusion about whether and how to deduct the freight for the inland section of multimodal transport.

Is the inland freight rate related to the import duty-paid price?

According to Article 3 of the "Guidelines for the Valuation of Imported Maritime Transportation and Related Expenses" (hereinafter referred to as the "Guidelines"), transportation and related expenses included in the dutiable value of imported goods must meet the following three conditions at the same time: first, it is related to transportation; second, it is related to transportation; It should be calculated until the goods arrive at the import place in the People's Republic of China and be unloaded; third, it is actually paid and should be paid by the buyer.

According to the nature of the freight for the inland section of import transit, the above conditions are compared one by one: first, the freight for the inland section is indeed related to transportation, and the conditions are met; second, the conditions are not met before loading and unloading at the domestic import point - take the maritime port as an example , when the main line transport enters the country (the dividing point of "before unloading"), that is, from the maritime port to the inland point branch line transportation, it is already after unloading; third, the buyer actually pays and should pay, which needs to be based on specific trade terms to judge.

According to Article 5 of the "Guidelines", there are two conditions for identification before unloading at the import point within the territory of the People's Republic of China: One is the domestic import location, which refers to after the international shipping vehicle carrying imported goods enters my country's customs territory, The place where the imported goods leave the means of transport for the first time; the other is before loading and unloading, which refers to before the loading and unloading of the goods begins.

The key point of the first identification condition is: the international navigation means of transportation and the imported goods leave the means of transportation for the first time. This can be judged that the inland port where the goods are transported in the inland section does not meet the definition of "input place"; the second identification condition mentions "Before loading and unloading" refers to the loading and unloading of cargo in the inland section before the act of loading and unloading (international shipping means of transportation), which does not meet the definition.

To sum up, according to Articles 3 and 5 of the "Guidelines", the inland section freight is not included in the duty-paid price.

How to deduct inland freight from the import duty-paid price

In reality, the main entities that can provide inland section freight information include: enterprises, third parties, and carriers. The specific situation is as follows:

First, due to trade term restrictions, it is difficult for companies to provide inland freight rates. Imports are usually based on CIP or CIF. Taking CIP Changsha as an example, the exporter (i.e. overseas seller) arranges transportation and pays the full freight to Changsha. The carrier signs a cargo transportation contract with the seller and has no transportation contract relationship with the domestic buyer. Therefore, it is difficult for domestic enterprises to obtain inland section freight information.

Second, due to fluctuations in freight rates in the inland section, the periodic deduction data provided by third parties can easily deviate from the actual freight rates. At present, some customs are exploring the use of third-party firms to collect inland section freight quotes on the market to form a relatively fixed inland section freight within a certain period of time and make deductions. The advantage of this is that it is simple and easy to implement, and both parties have relatively stable data to draw from.

But its disadvantages are also self-evident. First, fixed prices cannot reflect the real fluctuations in inland freight rates. Second, if the fixed price is higher than the real freight price, it will lead to a low duty-paid price and the loss of national tariffs; if the fixed price is lower than the real freight price, it will cause damage to the interests of the enterprise. Third, the price purchasing method of third-party firms will increase the administrative costs of customs. If all inland customs promote this model, customs involved in inland transit transportation will increase their expenses. Fourth, if it is containerized cargo, it is relatively convenient to fix the freight rate, but if it is bulk cargo, the fixed freight rate will differ depending on the type of cargo and ship type, making the operation more complicated.

Third, when the carrier issues a full multimodal transport bill of lading, it has a clearer and more accurate grasp of the inland section and the entire freight rate. At present, the customs supervision of carriers includes manifest management and transportation management. For import transit transportation, it is recommended to increase the carrier's inland section freight information transmission (declaration); at the same time, promote inland manifest management to better explore multimodal transport customs supervision.