Title
Customs Valuation and Compliance Regulations
Law
Boc Administrative Order No. 04-2004
Decision Date
Nov 8, 2004
The Customs Administrative Order No. 004-04 enhances and consolidates regulations for the valuation of imported goods, providing six methods for determining the dutiable value, implementing recordkeeping and post-entry audit systems, and imposing penalties for non-compliance.
A

Determination of Dutiable Value

  • Use six sequential methods for customs valuation.
  • Method 1: Transaction Value - based on the actual price paid or payable for goods sold for export to the Philippines with specific conditions ensuring value integrity and relationship neutrality.
  • Adjustments to transaction value include commissions, packing, assists, royalties, transport, loading/unloading, and insurance costs.
  • Exclusions from dutiable value include post-importation costs, Philippine duties and taxes, and other permissible deductions.
  • Importer must pay adjustments within 45 days of importation or payment.

Methods 2 and 3 – Transaction Values of Identical and Similar Goods

  • Method 2 uses transaction value of identical goods sold for export to the Philippines under similar commercial terms.
  • Identical goods must share physical characteristics, quality, reputation, origin, and producer.
  • Method 3 applies if identical goods value is unavailable; uses transaction value of similar goods with like characteristics and commercial interchangeability.
  • Adjustments allowed for commercial level, quantity, and transportation differences.
  • If multiple values found, the lowest is used.

Methods 4 and 5 – Deductive and Computed Values

  • Method 4 (Deductive): Based on resale price in the Philippines minus certain costs such as commissions, profits, taxes, and transport expenses.
  • Conditions include sales in the same condition or after further processing, unrelated purchasers, and an applicable time frame.
  • Method 5 (Computed): Based on the cost of production plus profit and general expenses.
  • Includes costs of materials, labor, packing, assists, engineering, and transport to import point.

Method 6 – Fallback Value

  • Applied when dutiable value cannot be determined under previous methods.
  • Uses reasonable means consistent with WTO principles and available data.
  • Prohibits use of domestic sale prices, minimum values, arbitrary or fictitious values.

Handling Doubts on Transaction Value

  • Customs must notify importer if doubts arise on declared transaction value.
  • Importer given opportunity to respond; communication can be written upon request.
  • If unresolved, customs proceeds to determine dutiable value using alternative methods.
  • Importer entitled to written explanation of customs valuation determinations.

Administrative Provisions

  • Reference values from published sources serve as risk management tools but not basis for valuation.
  • Currency conversion based on Bangko Sentral ng Pilipinas rates per Customs Memorandum Order No. 24-95.
  • Goods can be released under sufficient guarantee when valuation delays occur, excluding prohibited goods.
  • Importers may appeal customs valuation within 15 days following additional duty payment.
  • Liquidation of import entries is final after three years, except for fraud, protest, audit, or tentative liquidation.

Recordkeeping Requirements

  • Importers must keep import and business records for three years at principal business location.
  • Records include company structure, purchase documents, shipping/importation documents, manufacturing and sales data, and financial records.
  • Customs brokers must keep copies of importation records for three years.
  • Foreign language documents must be accompanied by certified English or Filipino translations.

Compliance Audit Procedures

  • Authorized customs officers may audit records at importer or broker premises with proper notification.
  • Audits cover document and financial flow, inventory, and business processes relevant to customs valuation.
  • Access denial is punishable, can lead to reassessment and penalties.
  • Non-cooperation presumes inaccurate declared value and grounds for reassessment using alternative valuation methods.

Scope and Conduct of Compliance Audits

  • Audits initiated based on risk management, detected errors, or voluntary requests.
  • Brokers audited primarily to validate importer client audits.
  • Audits governed by detailed procedural guidelines including notifications, planning, conduct, reporting, and monitoring.

Compulsory Acquisition of Undervalued Goods

  • Customs commissioner may acquire goods undervalued by 200% or more based on test values, if importer fails to justify valuation.
  • Payment for acquired goods must be made within ten working days.
  • Importers may appeal to Secretary of Finance and Court of Tax Appeals.
  • Acquired goods may be sold if appeal not filed or denied.

Administrative and Criminal Offenses

  • Failure to keep required records incurs administrative fines, hold orders, and possible imprisonment.
  • Denial of access to audit records results in contempt charges, reassessment, fines, hold orders, and criminal penalties.
  • Failure to pay correct duties after audit classified as negligence, gross negligence, or fraud, with corresponding fines and possible prosecution.
  • Voluntary disclosure before audit commencement may lead to compromise of fines except in fraud cases.
  • Confidential information obtained during audits protected by confidentiality rules; violations are prosecutable.
  • Appeals on penalty impositions follow Customs Code procedures.
  • Government prosecutions handled by Customs officers with Department of Justice involved in probable cause determinations.

Registration and Submission Requirements

  • Importers and brokers must submit general information and undertakings to maintain records and allow audits upon registration.
  • Import Entry and related declarations must be furnished to the Post Entry Audit Group.

Authority and Legal Provisions

  • Commissioner of Customs empowered to promulgate additional implementing rules.
  • Repeals inconsistent orders and provisions.
  • Contains separability clause ensuring validity in case parts are declared unconstitutional.
  • Effective 15 days after publication.

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