Customs hot topic sharing – Customs valuation and China export control regime海关估价与中国出口管制制度(CN中文)
In recent years, China Customs has strengthened the monitoring of tax risks in post importation stage, and more and more verification and inspection towards import and export companies are carried out by Customs. After the epidemic, the Customs has strengthened the systematic review of transfer pricing of large multinational enterprises at industry level, with focus on the enterprises who have "special relations” in import and export transactions and royalty arrangement, which has brought more risks and complexity to multinational enterprises’ daily operations.
China is in the process of establishing its new export control regime. While the historical dual-use item list remains, exports are no longer controlled at a product level; instead each transaction must be reviewed to against the new requirements. Moreover, since China’s Export Control Law was announced, a number of export control related regulations have been issued including Guidance on the Internal Control Program (“ICP”) and the Anti-foreign Sanction Law. The new export control regime therefore will bring quite a lot compliance considerations for high tech exporters.