The Compliance Lifeline of Agency Service Fee Invoices

After the implementation of Announcement No. 22 of the General Administration of Customs in 2025, a certain medical...Equipment ImportsDue to the misclassification of agency fee invoices, customs clearance was delayed by 28 days, resulting in a total of 1.27 million yuan in demurrage fees and breach penalties. This real-life case reveals:The handling of agency service fee invoices directly impacts the cost and timeliness of equipment imports..

Key Points for Invoice Type Identification

Three key types of invoices involved in the import process:

• Proforma Invoice
  • For advance payment application
  • Please indicate the wording "Not Final Settlement".
• Commercial Invoice
  • It must be consistent with the amount declared on the customs declaration form.
  • It is necessary to distinguish between equipment costs and service fees.
• Split Invoice
  • Applicable to installment payment projects
  • The original contract numbers must remain continuous.

New Regulations on Expense Processing for 2025

According to the latest customs valuation method by the General Administration of Customs:

• Alert threshold for agency fee proportionIncrease to 12% of the total contract amount
• Technical service fees need to be provided.Work Hours Record SheetFor reference
• Logistics surcharges must be listed separately.

Analysis of Typical Risk Scenarios

• Hidden Cost Trap
  • The "document processing fee" in a certain German equipment import contract is not clearly specified.
  • Resulting in an additional payment of 87,000 yuan in VAT during customs clearance.
• Blind spot of exchange rate fluctuations
  • A certain Japanese company did not stipulate a currency locking clause for invoices.
  • The exchange rate difference resulted in an overpayment of agency fees amounting to 230,000 yuan.

Professional Invoice Review Checklist

It is recommended that enterprises establish a three-tier review mechanism:

• Basic element verification
  • Completeness of buyer and seller information
  • HS Code and Customs Declaration Consistency
• Cost breakdown verification
  • The equipment cost and service fee are listed separately.
  • Royalties are separately identified.
• Policy compliance review
  • Method of indicating the standard of origin
  • Early Warning Indicator for Anti-Dumping Duties

Risk prevention operation recommendations

• Add to the agency agreementInvoice Dispute Resolution Terms
• Require agents to provideCustoms Pre-determination Supporting Documents
• EstablishE-invoice Comparison SystemAutomatic verification

An auto parts importer successfully avoided three customs price inquiries in the first half of 2025 by refining its invoice management process, saving 15 working days in customs clearance. Data shows that properly handled agency fee invoices can reduce overall import costs by 4.7%. It is recommended that enterprises refer to the 2025 revised edition of the "Guidelines for Price Declaration of Imported Goods" issued by the General Administration of Customs and update their internal audit standards quarterly.