Customs declaration and payment: how they connect and how to check it

The goods declaration is usually seen as the customs representative’s business, and the payment as the finance team’s. But the bank and customs look at the same figures from two sides. If the amounts in the declaration, the invoice and the payment documents differ, questions will come from both. Let’s look at how the declaration and the payment are linked and how to check the declaration.

What a DT is and which of its fields matter for the money

The goods declaration, DT (from its Russian abbreviation), used to be called the cargo customs declaration, GTD. It is filed when goods are imported, exported or moved in transit. More about the process: customs clearance.

For the payment side, these fields matter:

• the contract number and date, and if the contract is registered with a bank, its unique contract number (UCN);
• the invoice number and date;
• the currency and the invoice value;
• the delivery terms under Incoterms;
• the customs value and the method used to determine it;
• the customs procedure code: 40 for release for domestic consumption, that is, import, and 10 for export.

How the payment and the declaration are linked

There are two links.

The first is currency control. If the contract is registered under Bank of Russia Instruction No. 181-I, the bank keeps a bank control statement for it. Payments to the supplier and imported goods meet in that statement. You paid more than you imported and the delivery deadline has passed: you have an open advance. You imported more than you paid for: you have an open debt to the supplier.

The second is the customs value. The main method of determining it under the EAEU Customs Code is the transaction value method, that is, the price actually paid or payable. Payment documents confirm this price. If you paid through an agent, the confirmation is the agency agreement, the payment order, the agent’s report and the payment confirmation.

The customs value affects more than duties. Import VAT is also calculated on it, with the duty added. So an error in the value hits two payments at once.

For an exporter, the link is the same, but from the other side. An export declaration with procedure code 10 shows the bank that the goods have left, and the bank expects the proceeds within the deadlines in the contract.

How agent costs are treated in the customs value is for your customs representative to decide. The job of the payment side is to provide documents that show how much the supplier received and how much the fee was.

How to check a declaration by its number

The registration number of a DT consists of three parts separated by slashes:

• eight digits: the code of the customs office that registered the declaration;
• six digits: the registration date in day, month, year format;
• seven digits: the sequence number.

A number with a different structure is a reason for questions.

A company sees its own declarations in the foreign trade participant’s personal account on the website of the Federal Customs Service (FCS). Logging in requires a qualified electronic signature. If you are buying goods that have already been imported from a Russian importer, you can check their declaration through the online services of the Federal Tax Service, to which customs passes the data. These services do not show the full content of the DT, but they confirm that it was registered. Commercial foreign trade databases are useful for market analysis but are not official confirmation.

Matching against the contract, invoice and payments

The fact that the number is in the database does not yet mean that the declaration relates to your delivery. Check:

• the name and description of the goods against the contract and the specification;
• the quantity, weight and product range against the invoice and the packing list;
• the value and currency against the invoice;
• the delivery terms against the contract;
• the contract number in the DT against the number the payments were made under;
• the transport document: a bill of lading, a CMR consignment note or an air waybill.

The DT total must match the sum of the payments for this delivery. If there was an advance under a proforma invoice and the balance under a commercial invoice, the two payments together equal the invoice value.

Customs value adjustment

If customs doubts the declared value, it requests documents and may adjust the value. The duties and VAT are then recalculated and the difference is paid. An audit is also possible after the goods are released: the time limits are set by the EAEU Customs Code.

Common reasons:

• the price is lower than for similar goods from the same country;
• an incomplete document package, including payment documents;
• mismatches between the contract, the invoice and the DT;
• a long chain of intermediaries that makes the manufacturer’s price unclear.

Payment through an agent is not in itself a reason for an adjustment. But customs may ask how the payment was made. If the agreement, the payment order, the report and the payment confirmation are collected in advance, answering such a request is simple. An adjustment decision can be appealed to a higher customs authority or in court.

If you find discrepancies

An error in the declaration for goods already released is corrected by adjusting the DT through the customs representative. If the price or the volume of the delivery has changed, a supplementary agreement to the contract is signed first, and then the bank where the contract is registered is informed. The earlier a discrepancy is found, the easier it is to resolve.

This is a general overview. We will give you an answer on your deal after reviewing the documents and before the roubles are transferred.

For each payment, VEDmost puts together a package that serves both the bank and customs. We prepare the agency agreement and the payment order with the rate and fee, and you sign them with a company from our network. The payment confirmation, the completion certificate and the report come from the agent. More on the “Import payments” and “Currency control” pages.