Compliant definition of the procurement agency fees for imported equipment

Under the framework of the Measures for the Examination of Prices newly revised by the General Administration of Customs in 2025, two core conditions need to be met for the agency service fees to be included in the dutiable value:Whether it constitutes a sales requirementandWhether it is actually borne by the buyerIn practical operations, special attention should be paid to the following demarcation points:

• The distinction standard between independent third - party services and seller - related services
  • Verification of the independence of the signing subject of the service contract
  • Retrospective review of the capital payment path
• Assessment of the degree of correlation between the service content and the equipment procurement
  • Professional services such as the preparation of technical specifications
  • Basic services such as logistics and transportation

Preferred strategies for the inclusion path of agency service fees

Based on twenty years of practical experience, we recommend that enterprises choose the optimal inclusion plan according to the procurement mode:

• Plan 1: Inclusion in the CIF price in a packaged manner
  • Applicable scenarios: The seller designates the logistics service provider
  • Advantages: Simplify the customs declaration process
  • Risk points: May trigger price inquiries
• Plan 2: Separate itemized listing and independent payment
  • Applicable scenarios: The buyer independently selects the service provider
  • Advantages: Avoid double taxation
  • Technical requirements: Complete expense allocation sheets
• Plan 3: Post - period expense allocation mechanism
  • Applicable scenarios: Long - term equipment maintenance agreements
  • Advantages: Smooth out financial costs
  • Compliance key points: Documents for installment amortization

Key points for responding to the new customs valuation regulations in 2025

In response to the newly implemented Guidelines for the Examination of Special Relationships of the Customs, enterprises should pay special attention to:

• The mechanism of reversed burden of proof for related service fees
  • It is necessary to prepare complete qualification documents of service providers.
  • Retain the records of service provider selection for a three - year period.
• The acceptance criteria for digital payment vouchers.
  • The timestamp requirements for electronic payment statements.
  • Confirmation of the conversion base date for multi - currency payments.

Analysis of typical dispute cases

A certainMedical EquipmentA tax dispute of 3.27 million yuan arose in the import project due to improper handling of agency fees:

• The focus of the dispute: The nature determination of technical consulting service fees.
• Solution path:
  • Provide an independent third - party service agreement.
  • Supplement the list of technical delivery results.
  • Re - submit the chain of expense payment vouchers.
• Handling result: Successfully reduced the disputed amount by 82%.

The screening criteria for professional service providers.

When choosing a compliant agency service institution, the following aspects should be emphasized:

• The matching degree between the AEO certification level of the customs and the actual operation team.
• The compliance success rate of historical declaration data.
• The emergency response mechanism for dealing with customs price inquiries.
  • Average response time limit ≤ 2 hours.
  • The ability of professional customs brokers to accompany on - site inspections.