Special trade and customs inspections are mainly aimed at checking and evaluating the rationality of the design of internal control in customs, the effectiveness and adaptability of customs execution, and the compliance of customs execution. In terms of methods, it includes not only the compliance test of internal control in general audits, but also the substantive test and evaluation of customs processing of import transactions.
The purpose of trade and customs compliance testing is to understand the appropriateness of customs internal control design and the effectiveness of implementation, which can provide a basis for determining the scope and methods of subsequent substantive testing, and can also provide a basis for judging and evaluating customs risks and proposing improvements to customs internal control. Generally speaking, trade and customs compliance testing includes the following methods.
① Questionnaires and risk point checklists. According to the requirements and processes of trade and customs regulations, the matters that ensure customs compliance are listed one by one as the objects of investigation.
② Interviews and observations. Interviews include asking the management, internal audit department, heads of various business departments and operators to understand the degree of mastery of laws, regulations and internal policies by relevant personnel, understand the relevant internal processes and control measures from different departments, and understand whether the operators are operating in accordance with the specifications and processes. Since trade and customs affairs involve multiple departments, the control of a risk point requires the cooperation of several departments. Therefore, different departments need to be asked about the same matter, which can not only determine the real process (not just the process described on paper), but also determine whether the communication and cooperation between departments are coordinated.
Observation is to inspect the production sites and warehouses of the inspected units on the spot, which can help inspectors understand the problems that may arise in the production and storage process, such as the treatment methods of scraps and defective products in the production process, and whether the use of tax-exempt equipment is compliant.
③Testing of the internal management information system of the enterprise. If the internal management information system of the enterprise is reasonably designed, the compliance requirements of customs affairs can be directly reflected in the system design, and the customs declaration data and declaration reports can be directly extracted from the system, which will greatly reduce the errors that may be caused by manual work and the errors caused by manual judgment. However, if the design is unreasonable or inapplicable, system declaration errors will occur. According to the current customs supervision method for processing trade, online supervision or electronic account books are the direct connection between the ERP system and the customs declaration system. The design defects of ERP will directly lead to declaration errors.
If the enterprise has an internal declaration system and customs system, it can check the matching and accuracy of input and output data through “simulation test” or “sample test”, and check the rationality of “user management” and “security control” of the enterprise’s customs declaration system.
For processing trade enterprises, the following aspects can be focused on at this stage: ERP system design should distinguish between bonded materials and non-bonded materials; how the system controls the “switch” between bonded materials and non-bonded materials; how the system controls and reports the transfer of bonded materials to domestic sales; how to obtain the import price of bonded materials for domestic sales; how the bill of material (BOM) in the system is consistent with the unit consumption of networked supervision or electronic account books; how the outsourced processing and deep processing transfer systems can achieve effective coordination between different departments.
④ Procedure table for compliance testing. When conducting customs risk compliance testing, you can prepare test working papers, determine risk control points and control procedures one by one, and evaluate the control procedures based on the results of the measurement.