In the latest 2025 revision of the General Administration of Customsimport and exportMethods for Determining Customs Value of Goods,Import Representationthe accounting treatment of service fees has sparked industry debate. AMedical Equipmentcase where an importer paid 370,000 yuan in back taxes and late fees due to incorrect allocation of agency fees exposes cognitive blind spots in equipment value confirmation.
Three compliance bases for recording agency fees
Customs dutiable value determination criteriaClear requirements:
Agency service fees directly related to import activities
Transportation-related costs before equipment arrives at the domestic entry point
Additional customs clearance and inspection service fees that cannot be separately accounted for
According to 2025 special audit data from the Tariff Department, correctly including agency fees in equipment original value can reduce corporate comprehensive tax burden by an average of 2.3 percentage points.
Four-step practical operation method
Contract splitting
Separate listing of customs clearance service fees and logistics service fees
Technical consultation fees to be signed separately in supplementary agreements
Voucher management
Obtaining detailed service item lists recognized by customs
Maintaining complete payment flow evidence chain
Comparative analysis of typical cases
Case of an automation equipment importer adopting fee splitting solution:
correct operation: Including 150,000 yuan agency fees incurred before equipment debugging into original value, saving 42,000 yuan in taxes over three years
Incorrect operation: Similar companies including 200,000 yuan agency fees in period expenses, resulting in 38,000 yuan additional tariff and surcharges
Analysis of common cognitive misconceptions
Misconception 1:Small agency fee amounts dont affect tax calculation, Actual impact: Single fees may trigger dutiable value adjustment coefficients
Misconception 2:Tariff payment means subsequent processing can be ignored, Risk point: Depreciation period differences leading to income tax settlement disputes
2025 new policy response strategies
According to General Administration of Customs Announcement No.45, enterprises are advised to: