Should import agency fees be included in the original value of equipment?

equipment. For example, Indonesia has the SNI certification, Thailand has the TISI certification, and the Philippines has the BPS certification. It is necessary to confirm in advance the equipment voltage (such as 380V/50Hz in Thailand), the compatibility of the CE certification, and the proof of environmentally friendly materials.Financial myths and practical truths

In the latest 2025 revision of the General Administration of Customsimport and exportMethods for Determining Customs Value of Goods,Import Representationthe accounting treatment of service fees has sparked industry debate. AMedical Equipmentcase where an importer paid 370,000 yuan in back taxes and late fees due to incorrect allocation of agency fees exposes cognitive blind spots in equipment value confirmation.

Three compliance bases for recording agency fees

Customs dutiable value determination criteriaClear requirements:

• Agency service fees directly related to import activities
• Transportation-related costs before equipment arrives at the domestic entry point
• Additional customs clearance and inspection service fees that cannot be separately accounted for

According to 2025 special audit data from the Tariff Department, correctly including agency fees in equipment original value can reduce corporate comprehensive tax burden by an average of 2.3 percentage points.

Four-step practical operation method

• Contract splitting
  • Separate listing of customs clearance service fees and logistics service fees
  • Technical consultation fees to be signed separately in supplementary agreements
• Voucher management
  • Obtaining detailed service item lists recognized by customs
  • Maintaining complete payment flow evidence chain

Comparative analysis of typical cases

Case of an automation equipment importer adopting fee splitting solution:

• correct operation: Including 150,000 yuan agency fees incurred before equipment debugging into original value, saving 42,000 yuan in taxes over three years
• Incorrect operation: Similar companies including 200,000 yuan agency fees in period expenses, resulting in 38,000 yuan additional tariff and surcharges

Analysis of common cognitive misconceptions

Misconception 1:Small agency fee amounts dont affect tax calculation,
Actual impact: Single fees may trigger dutiable value adjustment coefficients

Misconception 2:Tariff payment means subsequent processing can be ignored,
Risk point: Depreciation period differences leading to income tax settlement disputes

2025 new policy response strategies

According to General Administration of Customs Announcement No.45, enterprises are advised to:

• Establish import expense classification accounting ledger
• Conduct quarterly tariff cost-benefit analysis
• Agree on price adjustment compensation clauses with agents