Eurotax’s customs department is dedicated to assist you in the optimization of your customs and supply chain function in France. Let us help you in designing your customs strategy.

Our objective is to assist companies of all sizes in the development of their customs strategy to standardize or improve the competitiveness of their global trade. The Union Customs Code (UCC) in effect since May 1st 2016 is full of opportunities but constitutes as well a source of risk factors to be anticipated. Indeed, if the Customs Special Procedures (or regimes) allow to optimize the customs cost of the storage, transformation and utilization of goods on an international scale, any company active on import / export must take the customs risk into consideration. If not yet convince, bear in mind the fact that customs audit which could be performed over a 3 years period of time in the past, can now be launched over the last 5 years. Plus, late payment interest are now generalized by the French Customs Administration.

The customs function must definitely be anticipated and planned. 

Within the framework of the definition of a customs strategy, its planification and implementation must be global and trasverse. The globality of your import and export flows must be taken into consideration and a sound and fair customs scheme must necessarily involve the information and / or contribution of several functions within the company (production, sales, procurement, accounts…).

Competitiveness and treasury gains together with a securisation of the customs risk : here after is an illustration of the missions that we perform for our clients.


AEO certification assistance

Two distinctive AEO authorizations are provided by the UCC :

  • AEO customs simplification (AEOC)
  • AEO security and safety (AEOS)
  • The combination of both is obviously recommended (former AEO Full).

The Authorized Economic Operator is recognized as a trusted company by Customs administrations but also by its peers, since it has satisfied criteria as defined by the European Commission such as appropriate record keeping, financial sovency, or compliance with customs and tax legislation and absence of criminal offences related to its economic activity. This AEO authorization is key to access the several UCC’s customs facilitation measures.

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Benefit of the AEO status AEOC AEOS
Easier admittance to customs simplifications  
Fewer physical and document-based controls

  • related to security & safety
  • related to other customs legislation
Prior notification in case of selection for physical control (related to safety and security)  
Prior notification in case of selection for customs control (related to other customs legislation)  
Priority treatment if selected for control
Possibility to request a specific place for customs controls
Indirect benefits
(Recognition as a secure and safe business partner, Improved relations with Customs and other government authorities; Reduced theft and losses; Fewer delayed shipments; Improved supply chain planning etc)
Mutual Recognition with third countries  

You would like to become an AEO company :

  • in order to improve your internal customs procedures
  • and / or to optimize your customs function

Qualified human resources for customs are pretty rare profiles, making the customs function not easy to internalize. In order to have a succesful and less time consuming AEO certification, Eurotax assists you in this methodic AEO certification process by performing namely the below steps  :

  • We help you defining the AEO certification perimeter (AEO C, S or both on the one hand, validation of part or totality of your locations to included in the AEO on the other hand) ;
  • We collect the required information and documents ;
  • We reconcile and organize the self-evaluation questionnaire as we progress in our work ;
  • We organize and lead interviews with the transversal functions of the company such as procurement, accounts, production and supply chain. We also prepare them all to the customs AEO audit where the administration will visit the premises and discuss with these various team;
  • Enventually, Eurotax assists you up to this on-site visit of French Customs administration and follow-up the finalization of the AEO validation.

Do not hesitate to engage your company in this certification process, strongly encouraged and positively recognized by French but also Chinese, US, Japanese, Norwegian and Swiss customs authorities*.

*Mutual recognition only allowed to AEO S traders. 


Customs Valuation, the trendy topic of French customs auditors

Together with Tariff classification and Origin, Customs valuation is one of the three essential notion to determine the customs treatment of a good. Customs valuation is often reassessed due to the lack of inclusions of molds or royalties cost, and in some circumstances the transfer price itself can be challenged when considered as “too low”.

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Principles

Customs valuation is determined by application of one of the evaluation method as defined in Articles 70 to 74 of the Union Customs Code (UCC).

As a principle, it corresponds to the transactionnal value in the sense of Article 70 of UCC that is the price actually paid or payable for the goods when sold for export to the customs territory of the Union, adjusted, where necessary of the elements mentioned in Articles 71 et 72 UCC. If and only if, the transaction value cannot apply, substitution methods must be tested in a chronological order.

Application

As an element of the calculation base of duties and taxes, the customs value declared for import is one of the most reassessed topic. Indeed, when goods are imported and where the transactional value applies, goods are in principle accompanied by an invoice showing only the price charged by the supplier while other dutiable elements invoiced and charged distinctively should be included in this customs value (such as the cost of the packaging, transport, insurance or even commissions of sales or royalties).

Besides, the transactional value could be rejected or non applicable (if the import does not result from a sale in the third country but is a simple transfer of stock for instance) the customs value is then determined by application of the secondary methods defined in Article 74 UCC : 

Identical goods methods, then similar, deductive or computed method and eventually the fall-back one.

In practice, as soon as a company perfomrs import of goods purchased from a company of same group in a third country, in case of payment of royalties or utilization of molds in relation to the imported goods, an audit or consistency check of customs valuation ought to be performed. The consequent infrindgements are indeed heavily penalized from a financial standpoint but also from a criminal law one.

Engage us to perform a customs valuation health check might predict huge customs risk. Contact us so we can define the perimeters of our intervention and provide you with a fee quote.


Implementation of Customs Special Procedures
    • Inward Processing Relief Goods will be introduced in France from a Third country (outside the EU) in order to be processed in France for transformation or repair work modifying their state / conditions. This regime alows to suspend VAT and customs duty normally due upon import in France.
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After the processing work, the regime is cleared either by the re-exportation of the processed goods or by release for free circulation in France (leading then to the payment of VAT and duties due on the whole processed good).

Example : a jewellery imports gemstones in order to assemble them to their golden ring in France. The jewel though finalized (the gemstone ring) is dedicated to the export market.

Should you import in France non-EU components or raw materials in order to process them in France and all (or part) of the finished goods is dedicated to export, do not hesitate any longer and contact us in order to benefit from substantials customs duty savings.

  • Outward Processing relief Goods will be exported out of France to a third country in order to be processed for transformation or repair work modifying their state / conditions. When the finished goods will return to France and be re-imported this regime allows to apply VAT and customs duty only on the value added outside the EU.
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Example : In the garment industry, a company ships out some fabrics in order for them to be cut and sewed in a Third country (outside the EU). The clothes though finalized are re-imported in France.

If you have transformation, production or repair work performed in a Third country on raw materials / component that you export over there before the finished goods is returned to France, do not hesistate any longer and contact us in order to benefit from substantials customs duty savings.

  • Customs Warehousing Goods are simply conserved in the same state (no utilization nor transformation) until an affectation or destination is known and exercised. Les marchandises sont simplement conservées en l’état, sans être ni employées, ni modifiées, dans l’attente de l’affectation à une autre destination douanière (sortie de l’entrepôt douanier soit mise en libre pratique, ré-exportation, rebus…). Only so-called “usual” manipulations are authorized.
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This regime allows treasury gains as it suspends the payment of customs duties and taxes on e.g. a whole stock upon import of a container. Duties and taxes will be paid progressively as the stock is withdrawn and then for instance, as the stock is sold.

Example : an e-commerce company imports a container of 10000 high-tech objects in France. Its maket is dedicated to the EU for 60% and export territories for 40%. Instead of cashing-out customs duties and taxes on the 10000 pieces upon import, it will only pay duties and VAT upon each shipments / order and this, depending on the destination (no duty nor VAT will be due for pieces sold to export non-EU countries).

Contact us for more information.

Contact us in order to define the best customs strategy with you.