Yona F. Maro
R I P
- Nov 2, 2006
- 4,202
- 218
Possible causes of TRA-Customs not collecting the projected revenues
- The lack of transparency and accountability related to the Customs process of the files declared to be equal or below FOB 2,500 USD. There are apparently a lot of entries declared to be below the FOB 2,500 USD threshold in order to avoid being thoroughly investigated by Tiscan. Although uplifted by Customs, the final Customs assessed value is apparently still well below what used to be assessed in the past by Tiscan. Apparently everybody is happy as Customs is reporting an uplift (even if it is not substantial) as well as the importers as they pay much less than they normally should. Even more it appears that Importers operate with two sets of documents one for Customs and one for Tiscan. They go ahead with Tiscan process until CVR stage. If they manage to process and obtain a release order from Customs they ignore/not use the CVR issued by Tiscan. In the eventuality they cannot process the file through Customs then they have no option but to use Tiscan CVR. We have been made aware that importers of used clothes shipments are one of the possible culprits. In order to find out the real situation Customs may be requested to provide TRA Senior Management statistics listing all the Customs entries covering FCL (Full container load) containers declared to be equal or below FOB 2,500 USD. Certain patterns may be observed (who are the importers/agents, who are the Customs officers usually involved in processing these files, which are the Customs entry points used by importers, ..etc)The stats should include the following details:
o Customs entry number
o Importer Name & TIN
o Agent Name & TIN
o B/L No
o FCL Container Nos
o Customs entry point
o Customs officer that processed/registered the entry and issued the Release Order
o FOB value declared by Importer/Agent
o FOB value assessed by Customs
o Description of the goods
o Quantity of goods
o Unit of measurement
o Currency
o Exchange rate against the currency stated on the Final Invoice
- Lack of feedback related to scanned ICD bound containers -
o ICD containers without a CVR/Un-known risk level: As per the procedures in place these ICD containers are scanned and the image stored until the Customs entry together with the related trade documents are receive by Customs at the Scanner site for the normal image analysis. It has been noted that Customs entries covering ICD bound containers are not reaching the Scanner site for the image analysis. As such one may wonder if these containers are still in the ICDs? Were they released? Where they inspected again at the ICD? Where there enough Customs resources to inspect? If inspected why, as long as these containers were already scanned?
o ICD containers with a CVR/Known risk level : In order to facilitate trade and the flux of containers from the port to the ICDs, containers covered by a CVR already issued are scanned on their way to the ICD. Having the CVR and all the related trade documents allows Customs to analysis the image and take a decision on the spot (release or inspect) without waiting for the Customs entry to reach the Scanner site (that sometimes may take days..). Without the Customs entry the scanning inspection results cannot be recorder by Customs in A++. The problem is that a lot of Customs entries never reach the Scanner site. It is then extremely difficult to know what actually happened with these containers after Scanning has been conducted. Were these containers released? Were they released on what basis? Were these inspected again? Were the Customs entry used to release these containers comparable with the CVR or it was one of those processed directly by Customs?
Some relevant figures related to scanned ICD bound containers:
Time frame: 7 April 2008 20 September 2008
Total number of ICD containers scanned = 5,442
Total number of ICD containers scanned and image analyzed (Customs entry made available on site) = 1,895
Total number of ICD containers scanned but image stored yet to be analyzed due to missing Customs entry = 3,547 / 65.2% of the total number of containers scanned
Total number of suspected containers out of the total number of containers scanned and image analyzed (1,895) = 318 / 16.8% of the total number of containers analyzed. No feedback received from Customs for any suspected container.
- The lack of transparency and accountability related to the Customs process of the files declared to be equal or below FOB 2,500 USD. There are apparently a lot of entries declared to be below the FOB 2,500 USD threshold in order to avoid being thoroughly investigated by Tiscan. Although uplifted by Customs, the final Customs assessed value is apparently still well below what used to be assessed in the past by Tiscan. Apparently everybody is happy as Customs is reporting an uplift (even if it is not substantial) as well as the importers as they pay much less than they normally should. Even more it appears that Importers operate with two sets of documents one for Customs and one for Tiscan. They go ahead with Tiscan process until CVR stage. If they manage to process and obtain a release order from Customs they ignore/not use the CVR issued by Tiscan. In the eventuality they cannot process the file through Customs then they have no option but to use Tiscan CVR. We have been made aware that importers of used clothes shipments are one of the possible culprits. In order to find out the real situation Customs may be requested to provide TRA Senior Management statistics listing all the Customs entries covering FCL (Full container load) containers declared to be equal or below FOB 2,500 USD. Certain patterns may be observed (who are the importers/agents, who are the Customs officers usually involved in processing these files, which are the Customs entry points used by importers, ..etc)The stats should include the following details:
o Customs entry number
o Importer Name & TIN
o Agent Name & TIN
o B/L No
o FCL Container Nos
o Customs entry point
o Customs officer that processed/registered the entry and issued the Release Order
o FOB value declared by Importer/Agent
o FOB value assessed by Customs
o Description of the goods
o Quantity of goods
o Unit of measurement
o Currency
o Exchange rate against the currency stated on the Final Invoice
- Lack of feedback related to scanned ICD bound containers -
o ICD containers without a CVR/Un-known risk level: As per the procedures in place these ICD containers are scanned and the image stored until the Customs entry together with the related trade documents are receive by Customs at the Scanner site for the normal image analysis. It has been noted that Customs entries covering ICD bound containers are not reaching the Scanner site for the image analysis. As such one may wonder if these containers are still in the ICDs? Were they released? Where they inspected again at the ICD? Where there enough Customs resources to inspect? If inspected why, as long as these containers were already scanned?
o ICD containers with a CVR/Known risk level : In order to facilitate trade and the flux of containers from the port to the ICDs, containers covered by a CVR already issued are scanned on their way to the ICD. Having the CVR and all the related trade documents allows Customs to analysis the image and take a decision on the spot (release or inspect) without waiting for the Customs entry to reach the Scanner site (that sometimes may take days..). Without the Customs entry the scanning inspection results cannot be recorder by Customs in A++. The problem is that a lot of Customs entries never reach the Scanner site. It is then extremely difficult to know what actually happened with these containers after Scanning has been conducted. Were these containers released? Were they released on what basis? Were these inspected again? Were the Customs entry used to release these containers comparable with the CVR or it was one of those processed directly by Customs?
Some relevant figures related to scanned ICD bound containers:
Time frame: 7 April 2008 20 September 2008
Total number of ICD containers scanned = 5,442
Total number of ICD containers scanned and image analyzed (Customs entry made available on site) = 1,895
Total number of ICD containers scanned but image stored yet to be analyzed due to missing Customs entry = 3,547 / 65.2% of the total number of containers scanned
Total number of suspected containers out of the total number of containers scanned and image analyzed (1,895) = 318 / 16.8% of the total number of containers analyzed. No feedback received from Customs for any suspected container.
