Managing your customs implications for retroactive transfer pricing adjustment in Asia

Singapore

  1. Would retroactive transfer price adjustment affect the customs value declared?

    Yes unless the company can prove the adjustment is not related to import price and/or goods.

  2. Is there any standard process to disclose the customs value adjustment to Customs
    • Retroactive upward adjustment in import price

      Most companies are eligible for administrative concession and not required to disclose TPA.

      Companies required to disclose a TPA include automotive vehicles importers and companies that cannot fully claim GST. In practice retroactive TPA for automotive vehicles importers is very complicated in Singapore.

    • Retroactive downward adjustment in import price

      Same as retroactive upward adjustment in Singapore.
       
  3. Lead-time

    1-3 months if a voluntary disclosure is required. The lead time depends on the complexity of such adjustments, amount of declarations affected, and customs officials' workload.

  4. When do you need to make the disclosure

    As soon as adjustment is done. Companies should assess whether they qualify for the administrative concession first before reaching out to Singapore Customs.

  5. Financial penalties applicable from Customs for failure to make the disclosure?

    Yes, financial penalties are rare but possible. The financial penalty per offence is capped at SGD 10k.
Follow PwC Asia Pacific Customs and Trade Practice