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Compared to implementing the Final Settlement Reports, reporting justification will be much more difficult. Currently, many companies do not have a clear division of labor for the department in charge of preparing the Final Settlement Reports. Regulations on coordinating between internal departments when preparing Final Settlement Reports have not received proper attention from companies.
To correctly prepare the Customs Final Settlement Reports, it needs to be based on actual data and evidenced by accounting vouchers and books of the company according to the accounting and auditing regime (Ministry of Finance). Data on customs declarations of processing and export manufacturing types are not sufficient basis for preparing the Customs Final Settlement Reports according to regulations of Circular 39.
According to regulations, the product norm report submitted to the customs authority is the actual norm of exported products in the year (according to Form 16/ĐMTT/GSQL promulgated with Circular 39). All information on the actual norms of exported products must comply with codes of raw materials, exported product codes in customs declarations. To properly understand and correctly prepare this norm report is also not easy for companies without a good internal management system.
Therefore, companies often encounter risks and errors in import-export-inventory management such as: Companies have not unified the main focal point department in charge of reporting activities to the customs authority; Not fully understanding the guidelines on information indicators in the Customs Final Settlement Reports (indicators related to company production activities - information on import-export activities is only for checking and reconciliation); Errors during customs procedures including commodity codes, place of origin codes on import and export declarations with codes at the accounting department, quantity and weight units (eg fabrics - kg/yard, etc.) and amended/cancelled declarations after customs clearance.
Errors in accounting: Separating commodity sources according to import-export categories: duty-free, non-taxable; trading and paying tax; domestic purchase and supply, etc.; Accounting codes of commodities, places of origin matching codes on customs declarations; Cases where customs procedures are not carried out but accounting vouchers still need to be retained.
And some other errors: Lack of linkage between the accounting/warehouse and import-export departments; Warehouse input and output (commodities + places of origin) excess/lack compared to information on customs declarations; Production activities occur in warehouses but the accounting department does not notify import-export; Commodities output for multiple purposes other than production (output exceeds technical norms but not accounted in production cost, output for domestic processing, output used for business operations, commodity sales, scrap sales, other outputs (destruction, gifts) but accounting does not notify import-export; Actual production differs from information reported to accounting: excess distribution and unreported retrievals, production shortage and unreported make-ups; Actual warehouse outputs exceed or lack in quantity or differ in type from customs declarations; Some goods output for purposes other than export but accounting does not account in account 155, but accounts in other accounts; Lack of consistency between warehouse and accounting leads to actual inventory quantity differing from inventory books and import-export inventory (causes cannot be determined).
Therefore, standardizing the import-export data management system according to processing and export manufacturing activities in companies is necessary. Firstly, companies need to issue codes for commodities, materials before carrying out processing, manufacturing and import-export activities based on the principle that all internal management departments use shared commodity, material codes.
The internal management system must be able to monitor warehouse input of materials (by import source with details by type of source and domestic purchase source), material use must be according to origin of formation of materials.
Finally, specifically assign duties to a department responsible for preparing the actual norm report of exported products, Final Settlement Reports according to Circular 39. Specifically identifying the main staff responsible for preparing the Customs Final Settlement Reports; staff in charge of preparing data for each column of the report; regulations on coordination in preparing the Customs Final Settlement Reports between departments.