A manufacturer may record the same imported materials in two sets of records: customs declarations and actual consumption norms maintained by the import-export team, and stock and cost records maintained by accounting. These records may use different systems, units and reporting dates. Reconciling them during the year helps identify differences before the annual customs finalisation report or a post-clearance audit.
Two departments, two versions of the same goods
| Import-export team | Accounting team | |
|---|---|---|
| Records | Customs declarations, HS codes, import regime, documented actual consumption norms | Purchase invoices, stock ledger, BOM and standard cost in the ERP, cost of sales |
| Unit of measure | Customs unit on the declaration | Inventory unit in the ERP – often different |
| Timing | Date of customs clearance | Date of receipt and invoice |
| Scrap and loss | Documented actual consumption, scrap and losses | Actual write-offs, often booked at year-end |
| Who reviews it | Customs: finalisation report, post-clearance audit | Auditors and the tax authority: CIT, VAT, transfer pricing |
Each record can be internally correct and still disagree with the other. Customs reads the finalisation report against the company's accounting books. Unreconciled differences can trigger further examination and, where the applicable conditions are met, a customs tax assessment and penalties.
An illustrative scenario
An export-processing manufacturer imports resin from its parent, tracks actual material consumption and exports most of its output back to the group. The import-export team files declarations in kilograms; the warehouse issues resin in bags; engineering changed the product design mid-year and updated the BOM, but the customs finalisation workpapers still use the old BOM without reconciling it to actual consumption. At year-end the customs finalisation report shows less resin on hand than the stock ledger – and the transfer-pricing review proposes a price adjustment on the same imports. (Illustrative facts.)
Each team has worked from a different record. Together these records produce three versions of the same goods, and the company has to explain the differences to customs, to the auditor and to the tax authority – separately, and often years later.
Common reconciliation gaps
- Opening balances do not match. The report starts from figures the accounting team never agreed; differences from earlier years roll forward.
- Actual consumption is not reconciled. Engineering changes the product and updates the BOM, but the annual customs finalisation still uses standard quantities without a reconciliation to actual consumption.
- Units and codes differ. Kilograms on the declaration, rolls or metres in the warehouse, with no agreed conversion table.
- Scrap and defects are undocumented. Losses are written off in the accounts without the records customs expects.
- Domestic sales and transfers are missed. Goods sold locally, transferred to another processor or used for a different purpose without the corresponding customs procedure.
The same import, reviewed in four areas
The misalignment does not stop at customs. When materials are bought from a parent company, the same transaction needs consistent support in four areas:
| Area | Reviewer | Typical mismatch |
|---|---|---|
| Customs value | Customs | Royalties, tooling or moulds supplied by the parent not added to the declared value; relationship influencing the price |
| Inventory and norms | Customs and auditors | Documented actual consumption norms, BOM and stock counts do not reconcile |
| Transfer-pricing result | Tax authority | A year-end price adjustment changes goods that cleared customs months earlier, with no supplementary declaration |
| CIT deduction | Tax authority | Adjustment booked with no invoice, agreement clause or settlement |
When applying Decree 255/2026/ND-CP, explain any differences between customs values and the prices used for transfer-pricing analysis, with consistent supporting records.
Making the two departments one process
- One item master. A single list of materials and finished goods with HS code, customs unit, ERP unit and conversion factor, owned jointly.
- Reconcile actual consumption with the BOM. Record production changes, scrap and losses, retain the calculation evidence, and notify actual consumption norms with the annual customs finalisation report.
- Monthly reconciliation, not annual. Declarations ↔ warehouse receipts ↔ stock ledger, with differences explained while the people and documents are still available.
- Scrap and loss on the record. Contemporaneous records of defects, destruction and loss that satisfy both customs and the auditors.
- Price changes go through both teams. No transfer-pricing adjustment is booked until its customs consequence is assessed.
- A dry run before filing. A draft finalisation report reconciled to the trial balance before it is submitted.
Where TASC fits
Differences can arise when customs and accounting records are maintained separately. Trade Advisory, Supply Chain & Customs (TASC) reconciles customs data with the accounts and reviews actual consumption norms and the finalisation report. Working with International Business Advisory (IBA), the team also examines differences between customs values and the prices used for transfer-pricing analysis, so that each reviewer receives consistent facts and explanations.
The company should be able to reconcile customs and accounting records and explain the basis for each difference.
Relevant capabilities: Trade Advisory, Supply Chain & Customs (TASC) · International Business Advisory (IBA)
General information as at October 2026. It is not legal, tax or accounting advice for any specific situation; check the law in force and your own facts before acting. The scenario is illustrative; treatment depends on the import regime and the rules in force at the time.
