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ИД «Финансы и кредит»






Finance and Credit

The customs procedure of duty-free trade: Methodological problems of indirect taxation and solutions

Vol. 27, Iss. 6, JUNE 2021

Received: 18 January 2021

Received in revised form: 22 March 2021

Accepted: 5 April 2021

Available online: 29 June 2021

Subject Heading: FISCAL SYSTEM

JEL Classification: H2, H25, M31

Pages: 1270–1291


Elena Yu. SIDOROVA Financial University under Government of Russian Federation, Moscow, Russian Federation


Aleksei A. ARTEM'EV Financial University under Government of Russian Federation, Moscow, Russian Federation


Subject. The article discusses customs payments made as part of sale and purchase deals for imported goods passing the duty-free trade customs clearance procedure.
Objectives. We study methodological aspects of indirect taxation in the sale of goods passing the duty-free trade customs clearance procedure, and determine economically reasonable consequences in common situations.
Methods. We use the graphic method, methods of comparison and observation to prove the reasonableness, reliability of methodological provisions and provide our reasoning on economically correct tax implications of indirect taxes as part of sale of imported goods subject to the duty-free trade customs clearance procedure.
Results. Setting forth effective rules for duty-free shops and the use of the duty-free customs clearance procedure, the government expected that goods be sold to outbound passengers. However, as the real situation shows, inbound passengers can also go for duty-free shopping. Some methodological issues and contradictions arose after the scope of the duty-free procedure changed. There are two types of deals in selling goods to a duty-free shop (the seller is a Russian resident in the first case, but not in the other). Furthermore, currently, duty-free shops may sell goods to each other, being in the Russian Federation, which also engenders complicated contractual schemes.
Conclusions. The paper outlines scenarios of selling goods to duty-free shops, and respective tax implications. We also consider the mechanism for charging taxes on deals involving goods subject to the duty-free trade procedure. In this study, we determine the taxation of other transactions that duty-free shops can make, out of the scope of the duty-free trade customs clearance procedure.

Keywords: customs procedure, customs payment, value added tax, excise tax, duty-free trade


  1. Pavlova D.S., Basharina A.S., Korshunova Yu.I., Tikhonova A.V. [Features of selling goods at duty-free shops]. Alleya nauki = Alley of Science, 2018, vol. 3, no. 4, pp. 752–753. (In Russ.)
  2. Taktarova S.V., Agamagomedova A.M. [Duty-free trade in the conditions of Eurasian integration: content and features of legal regulation]. Izvestiya vysshikh uchebnykh zavedenii. Povolzhskii region. Ekonomicheskie nauki = University Proceedings. Volga Region. Economic Sciences, 2018, no. 2, pp. 63–74. URL: Link (In Russ.)
  3. Labunskii D.V. [Directions for developing control over duty-free shops in the region of the Belgorod Customs Service]. Mezhdunarodnyi nauchnyi studencheskii zhurnal = International Scientific Student Journal, 2017, no. 4, pp. 196–200. (In Russ.)
  4. Davydova M.V. [Owners of duty-free shops as participants in activities in the field of customs affairs]. Vestnik Bryanskogo gosudarstvennogo universiteta = Bryansk State University Herald, 2020, no. 4, pp. 127–134. URL: Link (In Russ.)
  5. Kretova V.A., Dibrova M.S. [Customs procedure of duty-free trade: Essence, conditions of application and use in customs activity]. Nauchnyi zhurnal Diskurs = Scientific Journal Discourse, 2016, no. 1, pp. 253–258. (In Russ.)
  6. Ovechkin A.P. [Customs regulation of duty-free shops]. Tamozhennoe delo = Customs Affairs, 2017, no. 1, pp. 22–23. (In Russ.)
  7. Kozyrin A.N. [Free trade: customs procedure and its tax consequences]. Finansovoe pravo = Financial Law, 2016, no. 5, pp. 37–42. (In Russ.)
  8. Kozyrin A.N. [Customs procedure of a customs warehouse under the legislation of the EAEU and the Russian Federation]. Reformy i pravo = Reforms and Law, 2016, no. 2, pp. 8–15. (In Russ.)
  9. Pinskaya M.R., Artem'ev A.A. [Methodological problems and solutions of indirect taxation of broker operations in the EEU]. Natsional'naya bezopasnost' / Nota Bene = National Security / Nota Bene, 2018, no. 6, pp. 12–18. URL: Link (In Russ.)
  10. Sidorova E.Yu. [Formation of economically sound tax consequences on purchase and sale of foreign goods (case study on customs procedure of customs warehouse)]. Finansy: teoriya i praktika = Finance: Theory and Practice, 2020, vol. 24, no. 2, pp. 60–72. (In Russ.) URL: Link
  11. Sidorova E.Y., Goncharenko L.I. Tax Regulation of Customs Payments in the State Policy of Russia. In: Industry Competitiveness: Digitalization, Management, and Integration. ISCI 2019. Lecture Notes in Networks and Systems, vol. 115. Springer, 2020, pp. 636–642. URL: Link
  12. Pinskaya M.R., Artem'ev A.A. [Drawbacks of indirect taxation system in the Eurasian Economic Union and ways of their elimination]. Mezhdunarodnye otnosheniya = International Relations, 2018, no. 4, pp. 104–111. (In Russ.) URL: Link
  13. Goncharenko L.I., Malkova Yu.V., Balatskii E.V. et al. Sovershenstvovanie mekhanizma kosvennogo nalogooblozheniya v tselyakh obespecheniya finansovoi ustoichivosti pri soblyudenii balansa interesov byudzheta, biznes i naseleniya: monografiya [Improving the mechanism of indirect taxation to ensure financial stability while maintaining the balance of interests of the government, business and people: a monograph]. Moscow, RuScience Publ., 2020, 176 p.
  14. Vishnevskii V.P., Goncharenko L.I., Nikulkina I.V., Gurnak A.V. [Taxes and technologies: Past, present and future of the Russian tax system]. Terra Economicus, 2020, vol. 18, no. 4, pp. 6–31. (In Russ.) URL: Link
  15. Tkacheva T.Yu., Afanasjeva L.V., Goncharenko L.Iv. et al. Formation of Modern Fiscal Mechanisms: Integrated Approach. Proceedings of the 33rd International Business Information Management Association Conference, IBIMA 2019: Education Excellence and Innovation Management through Vision 2020. 33, Education Excellence and Innovation Management through Vision 2020. Granada, IBIMA, 2019, pp. 6955–6959.

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