1. The development of the group's bonded supervision model
1. In order to solve the bottleneck problem that restricts the development of processing trade in customs supervision, deepen the reform of "delegation of control and service", promote the free circulation of production factors and resource sharing among processing trade enterprises within the group, reduce enterprise institutional transaction costs, and help enterprises With the help of the processing trade bonded system to better face the international and domestic markets, the General Administration of Customs launched a pilot instruction for a new model of "Group Processing Trade Supervision" in the second half of 2019.
2. In January 2020, the General Administration of Customs formally deployed 9 customs offices in Tianjin, Shanghai, Nanjing, Xiamen, Qingdao, Jinan, Shenzhen, Guangzhou, Jiangmen, etc. to carry out a pilot project of "Enterprise Group Processing Trade Supervision Reform".
3. This mode can effectively support the enterprise to coordinate the production resources (materials) within the group to meet the needs of the enterprise group operation mode; participating enterprises can reduce the cost of working capital and shorten the adjustment cycle of manufacturing materials.
4. This regulatory model is a reform introduced by the General Administration of Customs in response to the needs of enterprise group management, unified procurement, unified production, and unified sales. It mainly solves the problem of free flow of processing trade goods between enterprises within the group.
5. In February 2021, the General Administration of Customs extended the pilot project of "Enterprise Group Processing Trade Supervision Reform" to the customs directly under the jurisdiction of the country.
2. Definition of Group Bonded Supervision Model
1. With the group as the unit and the information system as the carrier; guided by the actual operating needs of the group companies, the customs implements a processing and trade supervision model for the overall supervision of the group companies.
2. The customs uses the group's processing trade account book to monitor the goods flow and information flow of the "in, out, transfer, use, storage, and sales" supply chain of the group's processing trade goods; Data analysis is the management method" Canadian trade supervision model.
3. Conditions for companies to participate in the group bonded supervision model
1. The company has a general AEO certification or above.
2. The company's internal processing and trade logistics and data flow are transparent and clear, the logic chain is complete, and the consumption of materials can be traced to meet the customs supervision requirements (ie, it has an ERP system and a customs management system)
3. The company does not involve restricted Canadian trade goods
4. The policy dividends currently introduced by the group's bonded supervision model
1. Autonomous storage of bonded goods : Bonded goods can be independently stored in the place where the member company filed for the record
2. Free circulation of bonded materials: Bonded goods can be circulated autonomously in the places where member companies have filed for the record
1) This mode is that the customs actively conforms to market laws, meets the needs of enterprise group operation and development, and reduces institutional transaction costs for enterprises through innovating new models of processing and trade supervision, and stimulates their market vitality and creativity;
2) The autonomy of the enterprise has become stronger, achieving a win-win situation between the customs and the enterprise;
3. Self-management of exchange of materials: member companies can exchange and dispose of bonded materials, and between bonded materials and non-bonded materials. With the authorization and consent of the owner, the bonded materials for processing with supplied materials can be exchanged;
Note: The meaning of self-disposal is that bonded materials between member companies can be sold to each other through modes such as "deep processing carry-over" and "surplus material carry-over".
4. Outsourcing processing is more simplified: Outsourcing processing among member enterprises does not require customs filing, and all procedures among member enterprises for outsourcing processing are exempt from providing guarantees;
5. Autonomous deployment of non-priced equipment: non-priced equipment imported by an enterprise that is still in the supervision period can go through the equipment transfer procedures and be deployed and used among member enterprises;
6. Bonded goods are sold first and then taxed: Bonded goods can be sold domestically first, and tax collection procedures for domestic sales can be handled in a centralized manner according to regulations;
7. Diversified bonded guarantees: allow enterprises to provide guarantees to the customs in the form of deposits, bank or non-bank financial institution guarantees, enterprise group financial company guarantees, and insurance company guarantee insurance;
V. The pilot situation of the group bonded supervision model as of July 2021
1. Weifang Customs, Jinan Customs District:On February 17, 2020, Shandong Chenming Paper Group Co., Ltd. implemented the first "group processing and trade supervision" pilot. The group is a leading paper company in China and one of the top 10 paper companies in the world. The group has three operating and manufacturing companies in the Weifang jurisdiction , These three companies formed the "Group Processing and Trade Supervision".
The main preferential measures adopted:
a) Reasonable exchange of bonded materials between the three companies;
b) After the group obtains the authorization and consent of the owner of the processing materials, the bonded materials for processing processing are allowed to be exchanged;
c) Allow companies to purchase general trade imported materials nearby to supplement the gap in bonded raw materials
2. Jining Customs:On March 16, 2020, Shandong Sun Paper Co., Ltd. implemented the "Group Processing and Trade Supervision" pilot program, which is a processing and trading group with papermaking as its main business. The group has 2 subsidiaries.
The main preferential measures adopted:
Before: An enterprise received an urgent order. In the past, if the stock of bonded materials was insufficient, it could only passively wait for the import of materials, which caused some orders to be abandoned due to L/T problems.
Now: Bonded materials can circulate freely among group companies, and similar problems have been solved
3. Jiangmen Customs:Pilot implementation of two groups in the jurisdiction in January 2020
a) A Guangdong Electronics Co., Ltd. group has 14 production bases and 12 R&D centers around the world. Its products are exported to more than 130 countries and regions, with an annual turnover of more than 110 billion yuan.
The main preferential measures adopted:
1) The free flow of production resources within the group has been realized. The carryover of surplus materials and deep processing among member companies is no longer restricted. The exchange of incoming materials and parts can be exchanged after being authorized by foreign investors.
2) The outsourcing business of the whole process no longer pays the risk guarantee fund;
3) Subsidiaries can freely allocate materials from within the group when there is a shortage of materials and parts, and do not need to use funds to repurchase from abroad, which greatly reduces capital occupation and effectively solves the contradiction between the short order cycle and the long raw material order cycle.
b) A multi-layer PCB manufacturing group in Guangdong, which specializes in R&D and production of high-tech multi-layer high-density printed circuit boards; has five modern factories in Shenzhen, Jiangmen, and Dalian. In 2018, the circuit board production capacity exceeded 3 million square meters. Meter.
The main preferential measures adopted:
Before: Due to the mismatch between the customer’s P/O requirements and the production capacity of the different subsidiaries of the group, the Shenzhen subsidiary often needs to deliver some orders to the Jiangmen subsidiary for production; after the product is processed, the domestic sales will be taxed first, and then the Shenzhen subsidiary will be paid Handle export.
Now: It is possible to coordinate the internal production resources of the group, further release the production capacity, reduce the procedures for multiple transactions within the group and the taxation of domestic sales, and reduce the operating costs of the enterprise (it can save nearly one million yuan in tariffs each year).
4. Hefei Customs:In December 2020, the "Group Bonded" supervision model was implemented for Anhui Forklift Group Co., Ltd.
The main preferential measures adopted:
Group member companies realize the free circulation of bonded goods. The company saves 20 million yuan in bonded materials and 500,000 yuan in customs duties each year. The order response time will be shortened from the original 3 days to half a day.
5. Nanjing Customs:
a) In March 2020, two companies of the Panasonic Group (Suzhou Sanyo Energy Company and Panasonic Wuxi Energy Company) will be implemented as a pilot supervision model of "Group Bonded"; these two companies have similar products/imported materials, but they are divided into different categories. It belongs to the characteristics of customs/tax management in Suzhou and Wuxi.
Main methods used:
1. Set up a self-storage VMI warehouse in the "Suzhou Sanyo Energy Company", and the two companies will each set up a VMI warehouse account book, while keeping their current enterprise E account books.
2. The two companies dispatched vehicles to the self-storage VMI warehouse to allocate materials and parts in accordance with their respective production allocation instructions; if their own storage space is insufficient, the free circulation of bonded goods is allowed. Based on the characteristics of the public VMI warehouse, it has achieved a reduction in the amount of corporate liquidity occupied; at the same time, it has saved the lease/management fee of the external warehouse.
3. Since the two companies both keep their own E-books, they have no impact on the BOM management, ERP/financial management of the respective companies, and also have no impact on the local taxation and customs management statistics of the two places.
b) In November 2020, the "Group Bonded" supervision model pilot was implemented for Tongfu Microelectronics Group. The group is composed of three companies in Nantong, Suzhou and Hefei; they belong to Nantong Customs under Nanjing Customs and Luzhou Customs under Hefei Customs. The pilot is the first joint implementation across the first-level customs area.
The group has a variety of practical business problems such as business crossovers between group companies and changes in customer orders. At the same time, the group's internal bonded materials and parts in the Yangtze River Delta have greater business needs for the allocation and off-site storage.
Main methods used:
1. The customs implements the unified establishment of processing trade account books across regions and customs areas, allowing companies to store bonded goods in cross-customs areas within the group according to production, research and development, inspection and maintenance needs, and realize the freedom of bonded goods such as materials, semi-finished products, and finished products within the group circulation;
2. After the reform, the group member companies no longer need to go through the filing procedures with the customs for outsourcing processing business, and the customs no longer collects deposits for all outsourcing processing procedures;
3. Actual cost reduction: As of June 2021, a total of 874 inter-group bonded materials allocation and outsourcing processing have been carried out, which has reduced the use of margin funds by nearly 10 million yuan and saved logistics costs by 500,000 yuan.
6. Summary of the experience of local customs on the pilot group bonded supervision model
1. Hefei Customs
After the reform is implemented, companies can store bonded goods in cross-customs areas within the group according to the needs of production, R&D, and inspection and maintenance, and realize the free circulation of bonded goods such as materials, semi-finished products, and finished products within the group, without the need for frequent declarations between multiple account books. Transfer, greatly reducing the management time and management cost of the company. Imported parts are the company's strategic materials. The group or the joint-stock company is responsible for unified planning, unified procurement plans, unified allocation and use, which can minimize inventory and capital occupation and improve asset utilization. Rate. According to corporate statistics, using the "group bonded" model, the company saves 20 million yuan in bonded materials and 500,000 yuan in taxes each year, and the order response time has been shortened from the original 3 days to half a day.
2. Jinan Customs
a) The handbooks (accounts) of the three companies in the customs area that participated in the pilot project were merged to realize the unified management of bonded goods , which is conducive to the realization of economic, efficient and convenient management within the enterprise group. The international market changes frequently. The group frequently changes product types and technical specifications at the request of customers during the execution of the contract. Under the original model, manual changes, write-offs, and statistics need to be handled frequently. The procedures are cumbersome and the cost is high; When there is a huge need to organize the joint production of all companies in the group, according to the original requirements, it is necessary to separate the order processing enterprises for filing and separate customs declaration, resulting in waste of human resources and customs clearance costs. After achieving the unified management of the three enterprises in the customs area, it is estimated that the annual management cost and labor cost will be saved by more than 2 million yuan.
b) Using the pilot policy of enterprise group processing trade supervision reform, under the premise of ensuring compliance with regulations, guiding enterprises to reasonably exchange processing materials with imported materials to supplement the gap in bonded raw materials , solving the urgent needs of enterprises, and avoiding direct economic losses for enterprises. Tens of millions of dollars. Shenzhen: Implement enterprise group processing trade supervision reform, further streamline business procedures such as outsourcing processing, exchange of materials and parts, centralized handling of domestic sales taxation, etc., exemption of guarantee funds for all-process outsourcing processing among member enterprises of the group, and give full play to enterprise self-discipline management The role of the company is to reduce corporate institutional costs and help companies improve operational efficiency. At the same time, the exemption of guarantee funds directly reduces the occupation of corporate funds. The member companies carried out 505 batches of outsourced processing, involving a value of about 1.64 billion yuan, and an exemption of about 360 million yuan in guarantee money.
3. Guangzhou Customs
The free flow of bonded materials for processing trade between enterprises within the group effectively solves the pain points of the tight supply chain of the enterprises within the group, realizes the free flow of production resources within the group, and improves the production efficiency of the enterprise. For example, a group enterprise urgently needs nozzles and other materials for production, because the supplier’s material supply cycle is long and cannot meet the emergency production needs. After participating in the enterprise group processing trade supervision reform pilot, it has been transferred from other enterprises under the group through the surplus material carryover method. The batch of nozzle materials (12,000 pieces) meets the production needs. Another example is that the group company transfers a batch of imported gold jewellery processing surplus materials to other companies of the group, thereby better realizing the group's division of labor among internal subsidiaries.
7. Shenzhen Customs decided to fully promote the "Group Bonded" model in April
Shenzhen Customs issued the "Notice on Comprehensively Promoting Enterprise Group Processing Trade Supervision Model to Support the Development of High-end Manufacturing" on April 22. The eight facilitation measures proposed are as follows:
1. Bonded materials are freely circulated and shared within the group.
Enterprise processing trade bonded materials can be freely circulated and used among member companies (including the lead company, the same below) within the same group through "surplus material carry-over" or "deep-processing carry-over".
2. The storage place is shared within the group.
The processing trade goods of the enterprise can be independently stored in the place where the member enterprises of the same group have filed with the customs, and the corresponding records shall be made. The places include the business place where the customs registration and the processing trade business are filed with the customs.
3. Bonded materials can be exchanged within the group, and the pre-audit will be cancelled.
Enterprises can exchange between bonded materials and between bonded materials and non-bonded materials, and the exchanged materials should belong to member enterprises within the same group. Enterprises can exchange and dispose of materials that meet the conditions for exchange of materials and keep relevant records on their own. With the authorization and consent of the owner, bonded materials and parts processed by supplied materials can be exchanged.
4. There is no need to go through the filing procedures for internal and external processing of the group and no guarantee is required.
The member enterprises that carry out outsourcing processing business will no longer go through the filing procedures with the customs, and all the procedures for outsourcing processing will be exempted from providing guarantees. Enterprises should keep records of internal receipts and shipments in accordance with regulations. Finished products, surplus materials, leftovers, defective products, by-products and other processing trade goods that are sent out by member companies for processing may not be shipped back to the company.
5. Non-priced equipment is freely circulated and shared within the group.
The non-priced equipment imported by the enterprise that is still in the supervision period can go through the equipment transfer procedures and be deployed and used among the member enterprises of the same group.
6. Centrally handle taxation procedures for domestic sales.
Enterprises can first sell bonded goods in the domestic market, and they can complete the tax declaration procedures within 15 days after the end of the quarter, provided that the validity period of the manual or the deadline for writing off the account books is not exceeded.
7. Explore pilot diversified guarantee methods for processing trade.
Enterprises are allowed to provide processing trade business guarantees to the customs in the form of deposits, bank or non-bank financial institution guarantees, enterprise group financial company guarantees, and insurance company guarantee insurance.
8. Account book management enterprises do not need to carry out inventory check every year.
If the account book management is implemented, there is no need to carry out inventory check every year. After analyzing the risks, the customs determines the ratio of write-off at the factory and the ratio of the value of the order.
8. Some enterprises in Nanjing Customs have recently proposed new preferential measures that they hope to add to the "Group Bonded" model1. When the group enterprise is carrying out the deep processing carry-over business, whether the non-bonded materials in the products of the transferring party can realize the value-added tax refund;
2. Whether the group enterprise is within or outside the zone, it can have the qualification of "Global Bonded Repair". After the defective products generated after repair are filed with the customs, the enterprise can carry out environmental protection treatment in the country;
3. Whether the group enterprise can freely choose to make up the tax on the bonded defective products according to the status or according to the materials;
4. In the process of domestic sales of bonded finished products, the group's enterprises outside the zone can freely choose the mode of making up taxes on the basis of materials or on the basis of finished products like enterprises in the zone;
5. If the group's out-of-area companies are unable to correspond to imported batches, can they apply FTA benefits in the domestic sales tax reimbursement link;
6. Whether the group company can be based on the credit rating of the lead company, the customs shall apply to all member companies to reduce the frequency of audits and achieve a lower import and export inspection rate;
7. Whether the group enterprise can form a group linkage supply chain with the upstream and downstream supply chain.
The above points are related to the coordination between the customs and the taxation department. It is reported that Nanjing Customs is discussing the feasibility.
9. Customs interpretation of "group bonded" matters
1. What is an enterprise group?
Interpretation: An enterprise group refers to a corporate legal entity consortium of a certain size composed of a parent company with a capital as the main link and a parent company, a subsidiary company, and a shareholding company with a common code of conduct.
2. What is the supervision of enterprise group processing trade?
Interpretation: Enterprise group processing trade supervision refers to the processing trade supervision model implemented by the customs with enterprise groups as the unit, information system as the carrier, and the actual needs of enterprise group operations as the guidance, and the overall supervision of enterprise groups is implemented.
3. What is the lead company?
Interpretation: The lead enterprise refers to the enterprise that is authorized by the member enterprise to apply to the customs for the pilot enterprise group processing trade supervision. The lead company should be familiar with the internal operation and management model of the enterprise group, determine the scope of member companies, and coordinate the member companies to carry out related businesses.
4. What is a member company?
Interpretation: A member company refers to an enterprise within the same group that has obtained the qualification for the pilot group of enterprise group processing trade supervision.
5. How to apply for the "Group Bonded" model
Interpretation: The lead company submits an application for participation in the reform to the customs of its locality and submits the following materials:
A) Written application by the lead enterprise. The main content of the written application: It should truthfully state the general situation of the enterprise group, the list of leading enterprises and member enterprises, investment relations, and participate in the formal application for the reform of the enterprise group's processing trade supervision. It focuses on specific explanations on whether the pilot conditions are met: 1. Whether the member enterprises’ customs credit ratings are all certified or above; 2. Whether the flow of goods and data in the processing trade within the enterprise group is transparent and clear, the logical chain is complete, and the consumption The materials can be traced to meet the customs supervision requirements, and the internal management mechanism, system and internal management system can be briefly introduced; 3. Whether it involves processing trade goods that have restrictions on the qualifications of the enterprise.
B) The authorized entrustment signed and stamped by the legal representative of the member company. The main content of the authorization: the member enterprises entrust the lead enterprise to handle the related business of the enterprise group processing trade supervision reform with the customs.
C) The capital contribution relationship table or other certification materials of the member company. For example, relevant certification materials issued by the market supervision department, or foreign-invested enterprise approval certificates, legal person business licenses and other materials that can reflect the capital contribution relationship.
6. Do I need to re-establish the manual (account) book to participate in the pilot program?
Interpretation: Enterprises can use their existing hands (accounts) to participate in reforms, or they can set up hands (accounts) to participate in reforms. Enterprises can handle the establishment (change) of the hand (account) book through the "single window", and indicate in the remarks column of the hand (account) book: "×× group member enterprise, lead enterprise: ×× company, registration code: ××× ×".
7. How to withdraw from the reform of enterprise group processing trade supervision?
Interpretation: Upon confirmation by the lead company and the member companies involved, relevant member companies can apply to withdraw from the enterprise group processing trade regulatory reform; upon confirmation by the lead company and all member companies, the enterprise group can apply for withdrawing from the enterprise group processing trade regulatory reform.
8. How to handle the transfer business of bonded materials within the group?
Interpretation: Bonded materials for enterprise processing trade can be transferred and used among member enterprises within the same group. For the transfer of bonded materials between different hands (accounts) of the same group, the enterprise can handle relevant procedures by means of surplus material carry-forward or deep-processing carry-forward according to the actual situation.
A) Carrying over by surplus material
If the bonded materials need to be transferred, the transfer-out and transfer-in enterprises shall respectively declare the bonded verification and remark list according to the "surplus material carry-over" method, and indicate "the transfer of bonded materials within the group" in the remarks column.
B) Carry forward by deep processing
If the bonded materials need to be transferred, the transfering company will separately record the relevant goods in its hand (account) book as "finished products", and the product name, product code, specification and model, etc. shall be consistent with the corresponding materials, and the unit consumption is only corresponding If the material and the loss is 0, the remarks column of the finished product shall indicate "the flow of bonded materials within the group, corresponding to the serial number of the material ××". This finished item is dedicated for the transfer of bonded materials within the group. The transferring enterprise shall file the materials in its hand (account) book according to the current regulations.
The transfer-in and transfer-out enterprises shall respectively declare the bonded verification check list and customs declaration form in accordance with the method of "deep processing carry-over". The product name, product code, specification model and other product information in the documents of both parties should be consistent.
9. How to handle the exchange of materials and parts within the group?
Interpretation: Enterprises can swap between bonded materials and between bonded materials and non-bonded materials. The swapped materials should belong to the same group of member companies, and follow the same variety, same specifications, same quantity, and no profit the rules. Enterprises can exchange and dispose of materials that meet the conditions for the exchange of materials and parts, and keep relevant records. With the authorization and consent of the owner, the bonded processing materials can be exchanged.
The enterprise should summarize the exchange of bonded materials every month, pass the bonded verification list before the 15th of the following month, and declare to the customs in the order of "first export, then export", and the declaration time shall not exceed the validity period of the hand (account) book or write off. cycle. The supervision method of the relevant bonded verification list is "AAAA", and the remark column indicates "interchange of materials within the group", and the relevant retained information is attached.
10. How to go through outsourcing processing procedures?
Interpretation: To carry out outsourcing processing business among member companies, there is no need to declare the "Outsourcing Processing Declaration Form", and the actual receipt and delivery situation shall be recorded and kept by the enterprise in accordance with the regulations. Among them, the customs are exempted from receiving guarantees for all-process outsourcing processing. Finished products, surplus materials, leftovers, defective products, by-products and other processing trade goods that are sent out by member companies for processing, after the operating companies go through the procedures for export, deep processing carryover, domestic sales, and return, the relevant goods may not be Shipped back to the enterprise, directly from the contractor to the port or downstream enterprise.
To carry out outsourcing processing business with enterprises outside of the group, they shall apply for the "Outsourcing Processing Declaration Form" in accordance with the existing outsourcing processing regulations, and provide guarantees in accordance with the regulations for all-process outsourcing processing.
1. Can the Customs take the lead in applying the FTA policy to the group-bonded member companies outside the zone?
At present, China has signed large FTA agreements with many countries and regions, and the latest RCEP agreement with 15 countries including China/Japan/Korea/ASEAN is expected to be officially implemented in early 2022; it will reduce import costs and increase products for enterprises. Competitiveness helps a lot.
However, according to the current customs policy, domestic and foreign enterprises can only enjoy the preferential tax rate of the FTA agreement in the first-line goods import declaration (general trade) link; while the domestic and foreign trade enterprises first bond the import and then the domestic sales tax declaration is limited to customs operations. Confirm the inconvenience, there is currently no policy support to enjoy the FTA agreement. Although the Customs Announcement No. 51 of 2016 (Announcement on the Filling Regulations of Import and Export Goods Declaration Forms under Preferential Trade Agreements) has resolved the issue of domestic goods in special customs supervision areas/bonded areas enjoying FTA agreements, it has never resolved the issue of domestic and foreign goods The issue of enterprises' domestically sold goods enjoying the FTA agreement has brought resistance to the development of China's processing trade. Can we take the lead in exploring effective operation methods in the "group bonded" model to solve the problems that have plagued domestic and foreign enterprises for many years.
2. The problem of filling in the column of origin in the declaration of "deep processing carry-over" for materials under "Group Bonded"
One of the conveniences of "Group Bonding" is "Free flow of bonded materials between enterprises". After member companies have a circulation, they can use the "Deep Processing Carryover" model to settle mutual expenses; this is allowed by the "Group Bonded" model.
However, according to the current customs regulations, the "origin" column in the "deep processing carry-over" declaration form can only be filled with "China"; when it is filled in as overseas, the system will prompt an error. The definition of "deep processing carry-over" of "group bonded" has been given a new mode of settlement of materials borrowing and transferring expenses;
The “carry-over” goods have expanded from “finished products after manufacturing and processing” stipulated by the original customs to unprocessed “imported bonded materials”. Under this circumstance, if the correct place of origin of the material cannot be filled in the column of origin, the company's domestic sales will be supplemented later, and the account book verification will bring customs risks.
The practice of Changsha Customs is to fill in "China" in the "Origin" column of the "Deep Processing Carryover" declaration form, and fill in the correct country of origin of the corresponding materials in the "Attached" column. Whether this method of operation is appropriate is to be discussed and promulgated by the customs.
3. After the "Group Bonded" stipulates that "free transfer of bonded materials between enterprises", mutual enterprise fee settlement can also be carried out through the "surplus material carry-over" method
The current customs definition of "surplus material carry-over" is that the hand/account books of the same enterprise can be declared in the "surplus material carry-over" mode; the definition of "surplus material carry-over" in "group bonded" has been extended to "group bonded" The member companies, that is, the consignee/consignor can be different.
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