Title
Dutiable Value Basis Shift to Transaction Value
Law
Republic Act No. 8181
Decision Date
Mar 28, 1996
Republic Act No. 8181 changes the basis of dutiable value for imported articles in the Philippines from Home Consumption Value to Transaction Value, allowing for adjustments to the transaction value by adding certain costs incurred by the buyer, and providing alternative methods for determining the dutiable value if there is doubt or inability to ascertain it.
A

Verification and Alternative Valuation Methods

  • The Commissioner of Customs may demand further proof if the declared value is doubted.
  • Alternative valuation methods if transaction value is uncertain are applied sequentially:
    • Transaction value of identical goods.
    • Transaction value of similar goods.
    • Domestic unit price of goods or similar imported goods.
    • Computed value including raw materials cost, profit, expenses, freight, insurance, and related costs.
  • If none of the above can determine value, other reasonable methods consistent with GATT 1994 are used.

Publication and Protest of Values

  • Commissioner publishes determined values based on diplomatic and other information.
  • Values are binding until changed and must be published in widely accessible media.
  • Importers or interested parties have 15 days to protest a published value.
  • Protest decision must be made and published within 15 days.

Bond Filing for Delayed Determination

  • Importers may get goods released by filing a cash bond covering duties and taxes plus 25%.
  • Goods prohibited by law cannot be released even with bond.

Definitions of Critical Terms

  • "Reasonable doubt" defined as conditions leading to probable cause of an inaccurate invoice value.
  • Examples include prices dependent on other sales, extraneous forms of payment, and related party transactions.
  • "Related persons" include officers, partners, employer-employee, significant stockholders, controlled entities, and family members.
  • "Identical goods" means products identical in physical characteristics, quality, and reputation.
  • "Similar goods" share characteristics and materials to perform the same function and are commercially interchangeable.

Transitory Provisions Before Shift to Transaction Value

  • Until Congress authorizes full shift to transaction value, valuation is based on export value in principal export markets.
  • If export value unknown or doubtful, valuation progresses through markets of manufacture, third countries with similar economic development, and finally domestic wholesale price minus expenses, profits, taxes.
  • Similar publication, protest, and bond provisions apply during this period.

Early Shift to Transaction Value

  • Congress may mandate earlier shift to transaction value on presidential recommendation for national economy, welfare, or security reasons.

Rules and Delegation

  • Secretary of Finance, upon Customs Commissioner’s recommendation, will issue implementing rules.
  • Customs Commissioner may delegate duties of value determination and release under bond when no published values exist but must report and establish values promptly.

Hearing and Review of Published Values

  • Customs shall create bodies to receive protests and evidence on published values.
  • Hearing bodies submit recommendations; commissioner’s decisions are communicated and published.
  • Interested parties can petition to raise or lower published values any time during their effectivity.

Repealing Clause and Effectivity

  • Inconsistent existing laws and regulations are repealed or modified accordingly.
  • The Act takes effect 15 days after publication in official and general circulation media, whichever is earlier.

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