Inadequacies in financial Statements of export goods

Photo: Manh Hung

The imported goods being the imported raw materials and materials for the production of export goods belong to subjects that have to make annual financial Statements prescribed in Article 60 of Circular No. 38/2015/TT-BTC dated March 25th, 2015 by the Ministry of Finance. Accordingly, within 90 days from the last day of the fiscal year, enterprises importing raw materials and the materials for production of export goods have to make financial Statements of the fiscal year with the Customs Department managing these enterprises directly according to form No. 15/BCQT-NVL/GSQL Appendix V enclosed with Circular 38/2015/TT-BTC.

In order to have uniform financial Statements for production materials for export, in Section 1 of Letter No. 811/TCHQ-GSQL dated February 14th, 2017, the General Department of Customs requests the Customs Department of provinces and cities to guide enterprises to carry out procedures under the type of importing the raw materials for producing export goods: “making and submitting financial Statements according to the provisions of Article 60 of Circular No. 38/2015 /TT-BTC dated March 25th, 2015 of the Ministry of Finance and the guidance in the Letter No. 1501/TCHQ-GSQL dated February 29th, 2016 of the General Department of Customs.

Accordingly, the beginning inventory data, and the ending inventory data derived from the system of accounting books at the beginning and the end of the fiscal year (regardless of the time of application of the Law on Export and Import Duties)”, and Section 2.2 of the Letter No. 1501/TCHQ-GSQL dated February 29th, 2016 of the General Department of Customs also instructs: “The value reflected in the financial Statements is the original price of raw materials including: price on the invoice (Customs declaration), import tax, special consumption tax, value added tax for imported goods, environmental protection tax (if any), transport cost, loading cost, conservation cost, classification cost, insurance cost,… raw materials from the point of purchase to the storehouse of the enterprise, expense of the purchasing staff, the cost of the independent purchasing department, others related directly to purchase of raw materials and natural loss in the norm (if any)”.

However, when carrying out the financial Statements under the above-mentioned guidelines, the Customs office has received many reflections of enterprises about difficulties and problems in making financial Statements. Especially for heavy industry enterprises, products made for export are very large products weighing hundreds of tons, as big as dozens of high-rise buildings valued at tens of millions of dollars (such as seawater filter machine for fresh water, and boilers of the Vietnam Doosan Heavy Industries Ltd, Co), it is unlikely that the enterprise can enter inventory into the account 155 for products which the enterprise manufactured itself because there is no warehouse containing products with that large scale. For the cost, the enterprises manage the raw materials and inputs under each production project for export, so they do not also enter into account 152 as same as the production for export for other small products.

For example, in the fact, imported goods for export from Vietnam by Doosan Heavy Industries Co., Ltd included imported goods in direct service of production for each production project for export, the enterprise entered into account 621 and imported goods for production used for many projects, the enterprise entered into account 152. Account 621 is the account without balance at the end of the period (inventory).

Therefore, for imported raw materials for export production of this company, the accounting department cannot provide input - output - inventory data at the original value of raw materials to report according to form 15 Appendix B of Circular 38/2015/TT-BTC as well as the requirements of the current regulation. Input - output - inventory raw materials will be monitored by the workshop and the importing department in terms of quantity and value on the declaration form.

Regarding export products, because the heavy industrial products are very large and have been produced over a long period of time, perhaps many years, so, the company has not managed finished products into the warehouse, has only managed according to schedule or right after production.

With the above characteristics, goods imported for production of export goods in heavy industry shall be managed under each production project for export, the request for settlement report according to form No. 15/BCQT-NVL/GSQL Appendix V enclosed with Circular 38/2015/TT-BTC and the current guidelines could not be implemented, these cases need specific guidance for implementation which may allow enterprises to report under Form 15/BCQT-NVL/GSQL mentioned above, but according to the quantity of each type of raw material imported for export production same as the financial statement for processed goods instead of reporting the original value of raw materials under the current guidance, or in cases that are not allowed to report by quantity, it is possible to report by value on export – import declaration.

This would solve the problems of the financial Statements for the export production of heavy industry products absolutely and satisfactorily.