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Methodological considerations on the point of sale of goods for sale–purchase of imported goods undergoing the customs warehousing procedure

Sidorova E.Yu. Financial University under Government of Russian Federation, Moscow, Russian Federation ( Ejsidorova@yandex.ru )

Journal: International Accounting, #12, 2019

Subject The article examines the point of sale of goods (POS) in sale–purchase of imported goods undergoing the customs warehousing procedure.
Objectives The study specifies the POS as a concept in the context of the customs warehousing procedure and makes suggestions on amending legislative regulations.
Methods Research involves regulatory approaches, general scientific and special methods, such as a systems analysis, observation, and tool-based techniques of grouping, sampling, comparison and generalization.
Results As set forth in Article 147 of the Russian Tax Code, the contractual model implies no VAT, since customs warehouse is not qualified as the point of sale for purposes of Chapter 21 of the Russian Tax Code. I analyzed views of the Russian Ministry of Finance denying the emergence of a taxable item in Russia and, correspondingly, other tax implications from the sale of goods undergoing the customs warehousing procedure or stored there. The Russian Ministry of Finance expresses such views referring to the Russian Tax Code, which stipulates that the sale of goods in Russia is subject to VAT. I believe that, when goods are sold during customs warehousing, VAT shall be payable upon each subsequent sale, since Russia can be qualified as the POS.
Conclusions and Relevance To implement my concept, provisions of Article 147 of the Russian Tax Code should be specified so as to avoid that Russia be not recognized as the POS of goods when goods are actually sold during the customs warehousing procedure in Russia-based facilities.


Cost effectiveness of imposing reasonable tax implications as part of the tax warehousing procedure to enhance the resilience of the State and business units

Sidorova E.Yu. Financial University under Government of Russian Federation, Moscow, Russian Federation ( Ejsidorova@yandex.ru )

Journal: International Accounting, #1, 2020

Subject Research focuses on customs payments as part of sale–purchase deals with imported goods undergoing the customs warehousing procedure.
Objectives The study elaborates a technique to evaluate the cost effectiveness of imposing reasonable tax implications as part of the customs warehousing procedure in order to enhance the resilience of the State and business units.
Methods I rely upon a normative approach, general and special methods of research, such as a systems analysis, observation, tool-based techniques of grouping, sampling, comparison and generalization, to ensure the reasonableness, reliability and validity of methodological clauses determining the place of sale of goods as part of sale-purchase deals with imported goods undergoing the customs warehousing procedure.
Results The study presents my technique to evaluate the cost effectiveness of imposing reasonable tax implications as part of the customs warehousing procedure in order to enhance the sustainability of the State and business units. Based on examples, I refer to six cases. I showcase situations with excisable and non-excisable goods and fixed and ad valorem tax rates. This, in case of excisable goods, the strongest economic effect is recorded when customs duties on import are assessed at the fixed rate, while the ad valorem rate works for excise taxes. In case of non-excisable goods, the fixed rate is more beneficial. My suggestions will help improve fiscal functions of customs payments.
Conclusions and Relevance The proposed modifications of the customs warehousing procedure have a positive effect on the State and business units, making them more resilient, boosting fiscal revenue from additional tax implications from VAT, ensuring a simpler VAT control scheme and setting non-ambiguous tax implications for ordinary sale–purchase deals. This decreases tax rates for the State and business units.


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