What types of transit trade businesses can be carried out under the sea-rail combined operation mode?

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I am the person in charge of a foreign trade enterprise mainly engaged in the export of mechanical and electrical equipment based in Zhejiang Province. Recently, we received a large order from a Southeast Asian client, who requires us to adopt transit trade to circumvent the high anti-dumping duties in the destination country. We only operated sea-based transit trade models before.

We heard that the sea-rail combined transit trade features higher efficiency and lower cost, but we have no idea about the compliant transit trade types under this mode, and are also worried that improper mode selection will trigger customs valuation disputes, loss of cargo ownership or blocked tax refund. We hope professionals can introduce in detail the applicable sea-rail combined transit trade types for mechanical and electrical products of our kind, as well as the corresponding operation key points.

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Expert Answer

Robert
RobertYears of service:6Customer Rating:5.0

Warehouse Management AdvisorStart a Chat

First of all,it shall be clarified that the core of sea-rail combined transit trade is to rely on the "sea transport + railway" intermodal network to complete operations such as document exchange and cargo reorganization in a third country,which is mainly divided into three compliant models.

The first category is the bonded warehouse transit model: The cargo is transported to the bonded warehouse of a third country (such as the bonded zones at Port Klang in Malaysia,and Ho Chi Minh Port in Vietnam),connected to inland railway hubs via sea-rail intermodal transport,then undergoes container change and relabeling in the bonded warehouse before being shipped to the destination country via sea transport. This model is suitable for large cargo such as mechanical and electrical equipment,which can circumvent the anti-dumping duties of the destination country,and the whole process remains in the bonded status without paying import duties of the third country.

The second category is the transit transshipment model: Relying on cross-border railway trunk lines such as China-Europe Railway Express and China-Laos Railway,the cargo is dispatched from domestic railway stations to the transit port of the third country,then connected with sea transport to the destination country. The whole process does not enter the bonded zone of the third country,and only transit document exchange operations are conducted. This model delivers the highest efficiency,suitable for mechanical and electrical products with high timeliness requirements,but it is necessary to ensure that the third country allows transit and the documents meet the requirements of the customs of the transit country.

The third category is the processing transit model: If the mechanical and electrical products require simple processing (such as replacement of spare parts,packaging adjustment),the processing can be completed in the free trade zone of the third country,and then the cargo will be sent to the destination country via sea-rail intermodal transport. This model needs to meet the processing value-added rate requirements to avoid being identified as direct transit trade,and document filing of the processing links shall be completed in advance.

Key points to focus on during operation: Confirm the qualification of the third-country transit agent in advance,ensure that it has the capability of sea-rail intermodal connection,all documents shall keep consistent with "cargo flow,document flow and capital flow" to avoid triggering customs risk control,for mechanical and electrical products,documents such as the certificate of origin of the third country and packing list shall be prepared in advance.

John
JohnYears of service:6Customer Rating:5.0

Export Tax Rebate AdvisorStart a Chat

The core of customs declaration for sea-rail combined transit trade lies in "two declarations and one transit", and three key nodes shall be noted. The first is domestic export customs declaration: it shall be declared as "transit goods" explicitly, rather than direct export to the destination country, to avoid subsequent tax refund or valuation disputes. The second is the transit customs declaration in the third country: if adopting the bonded warehouse model, it shall be declared as "bonded warehouse goods"; if adopting the transit model, it shall be declared as "transit goods", and ensure the transportation method marked on the customs declaration is "sea-rail intermodal transport".

The last is import customs declaration in the destination country: documents such as bill of lading and certificate of origin after transit in the third country shall be used to avoid the customs tracing back to the country of origin. In addition, attention shall be paid to the valuation link: if there is processing value-added of mechanical and electrical products in the third country, processing cost vouchers shall be provided to avoid the customs valuating the goods according to the price of the country of origin. If there is a need for declaration cancellation and re-submission, the manifest information of sea-rail intermodal transport shall be adjusted synchronously to ensure the closed loop of document logic.

Daniel
DanielYears of service:8Customer Rating:5.0

Legal AdvisorStart a Chat

Logistics path optimization of sea-rail combined transit trade shall focus on cargo ownership control and cost reduction. First of all, transit ports with mature sea-rail intermodal networks shall be selected. For example, Port Klang in Malaysia connects to China-Laos Railway and China-Europe Railway Express, and Ho Chi Minh Port in Vietnam connects to Pan-Asia Railway, which ensures stable transit timeliness. Secondly, in terms of cargo ownership control, order bills of lading shall be adopted, and the endorsement shall be transferred to the destination country customer only after the transit is completed, so as to avoid loss of cargo ownership midway. Meanwhile, the free storage period and demurrage standard of the third country shall be confirmed in advance.

The free storage period of general bonded warehouses is 14-21 days. If the period is exceeded, extension application shall be submitted in advance to avoid extra costs. In addition, for large cargo such as mechanical and electrical equipment, containers suitable for sea-rail intermodal transport such as 40HQ high cube containers shall be selected, to meet the weight limit requirement during railway transport and avoid the risk of cargo being left behind or overbooking. If port change is required, the transit agent shall be notified 72 hours in advance, and the manifest of sea-rail intermodal transport and railway train schedule information shall be adjusted synchronously.

Emily
EmilyYears of service:3Customer Rating:5.0

Client Success AdvisorStart a Chat

The core of tax planning for sea-rail combined transit trade lies in making use of the third country's preferential tax policies and VAT deferral mechanism. First of all, if adopting the bonded warehouse transit model, you can enjoy the third country's VAT deferral policy, and do not need to pay import VAT during transit, only make declaration when the goods leave the bonded warehouse. Secondly, if adopting the processing transit model, you shall ensure the processing value-added rate meets the rules of origin standard of the third country (generally over 30%), so as to enjoy tariff preferences of the destination country, and avoid being identified as goods originating in China.

In addition, attention shall be paid to cross-border related party transaction pricing, to ensure the profit distribution of transit trade complies with BEPS rules, and avoid being identified as profit transfer by tax authorities. For mechanical and electrical products, the tax cost in the processing links, including processing tax fees in the third country and VAT deduction quota, shall be calculated in advance, to ensure the overall tax cost is lower than the anti-dumping tax cost of direct export.

Sophia
SophiaYears of service:7Customer Rating:5.0

Senior Customs AdvisorStart a Chat

Compliance of receipt and payment of foreign exchange in sea-rail combined transit trade shall ensure the consistency of capital flow, cargo flow and document flow. First of all, cross-border RMB settlement (via CIPS system) can be adopted to avoid exchange rate fluctuation risk, and ensure the foreign exchange receiving account is a compliant offshore account or NRA account.

Secondly, the receipt and payment of foreign exchange for transit trade shall be completed in the same bank, and the receipt and payment amount shall be consistent with the amount on the bill of lading and invoice, to avoid the suspicion of capital reflow. In addition, attention shall be paid to the filling of SWIFT message: "transit trade" shall be marked explicitly, and the transit bill of lading, certificate of origin of the third country and other documents shall be attached, to avoid being listed as suspicious transaction by the bank.

For large orders of mechanical and electrical products, the background materials of transit trade, including customer order and transit agent agreement, shall be reported to the bank in advance, to ensure the smooth completion of foreign exchange receipt and payment. If there is a problem of foreign exchange settlement and account reconciliation, the document information shall be adjusted synchronously to ensure the logical consistency of capital flow and document flow.

Sarah
SarahYears of service:3Customer Rating:5.0

Foreign Exchange AdvisorStart a Chat

Legal risk prevention and control of sea-rail combined transit trade shall focus on three core links. First of all, the transit agent agreement shall clearly specify the ownership of cargo, transit responsibilities and breach liability. Especially for high-value goods such as mechanical and electrical equipment, the compensation standard for cargo damage during the transit period shall be specified.

Secondly, soft clauses in letter of credit shall be avoided, such as "providing certificate of origin confirmed by the customs of the destination country", to ensure the documents can be submitted smoothly. In addition, intellectual property customs protection record-filing shall be completed, to avoid the patent or trademark of mechanical and electrical products being infringed in the transit country or destination country.

If force majeure events occur (such as railway suspension, port strike), the clause shall be specified in the agreement to clarify responsibility division and loss compensation method. For bill of lading endorsement in transit trade, blank endorsement or special endorsement shall be adopted to avoid cargo ownership disputes.

Charlotte
CharlotteYears of service:4Customer Rating:5.0

Currency Exchange AdvisorStart a Chat

On-site inspection of sea-rail combined transit trade shall focus on three links. First of all, during domestic export inspection, the packaging and identification of mechanical and electrical products shall meet the requirements of sea-rail intermodal transport, to avoid being rejected by railway departments due to unqualified packaging.

Secondly, during transit inspection in the third country, if adopting the bonded warehouse model, the seal of the cargo shall be kept intact, to avoid being identified as cargo replacement by the customs; if adopting the transit model, cooperate with the customs to complete the X-ray inspection, and provide operation manual of mechanical and electrical products, packing list and other documents, to avoid unpacking inspection. In addition, during import inspection in the destination country, the certificate of origin of the third country, processing voucher and other documents shall be provided, to avoid the customs tracing back to the country of origin.

If the laboratory report is abnormal, the material certificate of mechanical and electrical products shall be provided in time to ensure smooth inspection pass. For seal authenticity verification, regular seal suppliers shall be selected to avoid using counterfeit seals to trigger customs risk control.

Ella
EllaYears of service:10Customer Rating:5.0

Senior Financial AdvisorStart a Chat

The packaging of sea-rail combined transit trade shall meet the dual requirements of sea transport and railway transport. First of all, large goods such as mechanical and electrical equipment shall adopt moisture-proof and reinforced packaging, and use wooden pallets or steel pallets, to ensure the goods will not be damaged by vibration during railway transport. Secondly, if the product is dangerous mechanical and electrical product (such as equipment with built-in battery), MSDS document meeting UN standards shall be compiled, and UN dangerous goods packaging shall be adopted, to ensure the compliance of sea transport and railway transport. In addition, the identification shall be adjusted according to the packaging requirements of the third country.

For example, Malaysia requires warning labels marked in Malay on the package, and Vietnam requires origin labels marked in Vietnamese. For fragile mechanical and electrical parts, buffering packaging materials (such as foam, air cushion) shall be used for filling, to avoid collision damage during transit. If repackaging is required, it shall be completed in the bonded warehouse of the third country, and packaging records shall be kept, to ensure the consistency of documents and packaging.

William
WilliamYears of service:10Customer Rating:5.0

International Logistics AdvisorStart a Chat

Export tax refund of sea-rail combined transit trade shall ensure the consistency of four flows. First of all, during domestic export customs declaration, it shall be declared as "transit goods". It shall be noted that transit trade does not fall into the scope of export tax refund. If adopting the processing transit model and the goods are processed in China, the tax refund can be applied for as export processed goods.

Secondly, the consistency of capital flow and document flow shall be ensured, the amount of foreign exchange received shall be consistent with the amount of export invoice, to avoid the suspicion of capital reflow. In addition, document filing shall be completed, including manifest of sea-rail intermodal transport, transit agent agreement, certificate of origin of the third country and other documents, to avoid failing to provide materials during tax verification.

For mechanical and electrical products, the declaration deadline of tax refund shall be confirmed in advance, which is generally within 90 days after export. If the deadline is exceeded, extension application shall be submitted. If the pre-declaration verification fails, the information such as transportation method and HS code on the customs declaration shall be checked for accuracy.

David
DavidYears of service:3Customer Rating:5.0

Business Development AdvisorStart a Chat

Supply chain planning of sea-rail combined transit trade shall focus on precise cost calculation and inventory linkage. First of all, a precise cost calculation model shall be established to calculate the freight, transit fee, processing fee and other costs of sea-rail intermodal transport, and compare with the anti-dumping tax cost of direct export, to ensure the cost advantage of transit trade. Secondly, the inventory linkage strategy shall be optimized, link the inventory in domestic warehouses and third-country bonded warehouses, and prepare goods in advance according to order demand, to avoid transit delay. In addition, trade terms can be flexibly converted.

If adopting the sea-rail combined transit model, CIF transit port or FOB domestic railway station can be selected to reduce logistics cost. For large orders of mechanical and electrical products, the train schedule and shipping schedule of sea-rail intermodal transport shall be planned in advance, to ensure smooth transit connection and avoid cargo backlog. Meanwhile, pay close attention to the global supply chain fluctuation, such as tight railway capacity, port congestion, and formulate alternative plans in advance.

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