In the Communique published in early January, PwC provided an update process of the implementation of the UCC and, among other things, reported on the developments with respect to customs valuation. As such, we explained that the definition of the transaction value will change and advised companies to review what of these changes may be for their imports.
With respect to the new definition of transaction value, Dutch Customs gave some initial thoughts on the interpretation of the new definition. Those thoughts were given as initial comments to particular general situations that were described by industry representatives and will be further communicated by Dutch Customs during the road shows that will be held the coming months.
More specifically, in sessions between commerce and customs, the explanation of how to interpret structures with pre-ordering systems has been discussed. Questions did arise, such as in the initial thoughts, the pre-ordered transaction (i.e. the sale of the importer to the subsequent chain in the sale) was taken qualify as the transaction that occurs immediately before the goods were brought into the EU customs territory, and thus as the basis for appraisal.
After speaking with the Dutch Customs Valuation team it is apparent that these are initial thoughts, which still are subject to discussion. We will have such further discussions with Dutch Customs based upon our analysis later this month and will provide you with an update.
On March 3, 2016, USFIA and PwC will host a free webinar providing an update on the UCC. Click here to register.