Tax expenditures are a crucial component of international logistics costs. For complex and costly special container shipping (such as open-top containers, flatbed containers, and flat rack containers), traditional cost control focuses solely on negotiating freight rates and surcharges, often overlooking strategic tax planning. Through sound tax planning, companies can effectively reduce the overall cost of special container shipping and enhance their competitiveness while remaining legally and compliant.
I. Core Approach: Defining and Proving “Special Purpose”
The key to tax optimization lies in demonstrating to tax authorities that special containers and the goods they transport are intended for specific production or trade purposes, rather than for conventional use, thereby eliciting more favorable tax treatment. The key lies in integrating the four flows of “contract flow, goods flow, capital flow, and invoice flow” into a single entity, ensuring clear and traceable documentation.
II. Specific Strategies and Paths
1. Accurately Classify and Strive for Export Tax Rebates
Strategic Key Points: Many goods transported in special containers, such as large-scale complete equipment, heavy machinery, and steel structures, typically qualify for high tax rebate rates. Ensuring the accuracy of the HS code (Customs Commodity Code) when declaring goods is a prerequisite for receiving full and timely export tax rebates.
Operational Recommendations:
Collaborate closely with the finance and customs clearance teams to accurately determine the HS code based on the specific functions, technical specifications, and materials of the goods.
The high freight, lifting, and securing fees that may be incurred in special container transport are costs directly related to export sales. These costs should be properly incorporated into the free on board (FOB) price of the exported products, thereby increasing the total export sales volume and, in turn, the base for export tax rebates, generating more refund funds for the company.
2. Leverage the Temporary Duty Free Policy (ATA Carnet)
Strategic Point: For special goods temporarily exported for overseas exhibitions, testing, maintenance, or other purposes (such as large machinery and equipment for exhibitions or samples), you can apply for the ATA Carnet (Temporary Import Clearance Carnet). Operational Recommendations:
Goods exported using an ATA carnet are exempt from import duties and value-added tax (VAT) in the destination country, significantly reducing the tax costs of temporary special container transport.
After completion, goods must be re-imported on time; failure to do so will result in back taxes and potential fines. This policy is ideal for short-term cross-border projects, avoiding capital tie-ups and cumbersome tax refund procedures.
3. Plan import methods to avoid double taxation
Strategic Points: For equipment imported for large projects, if the “temporary import” or “lease import” conditions are met, different customs clearance methods can be selected to delay or reduce tax payments.
Operational Recommendations:
Temporary Import: Equipment used for installation, commissioning, and other purposes can be declared as “temporary import and export.” Upon providing a tax guarantee, import duties and VAT are exempted. The guarantee is refundable upon re-export of the equipment. This significantly alleviates cash flow pressures for businesses. Leasing Trade: If equipment is imported through leasing, the rental fee can be paid in installments over the lease term, along with customs duties and VAT, rather than paying the full amount of goods all at once. This allows for tax deferral and improves capital efficiency.
4. Optimizing Intra-Group Tax Costs through Reasonable Transfer Pricing
Strategic Key Points: Applicable to multinational groups. When providing special container transportation services between companies within the group, reasonable transfer pricing strategies can be used to retain more profits in countries or regions with lower tax rates.
Operational Recommendations:
Logistics companies within the group can charge manufacturing companies reasonable market prices for special container transportation. By establishing and filing transfer pricing agreements that comply with OECD principles in advance, a portion of profits can be legally deposited in low-tax countries or regions (such as Hong Kong and Singapore), thereby reducing the group’s overall tax burden.
III. Important Warning: Compliance is the Bottom Line of Tax Avoidance
It must be emphasized that all tax planning must be based on legality and compliance.
Authenticity: Transactions must be genuine; artificially fabricated transactions are prohibited. Complete documentation: All contracts, invoices, bills of lading, packaging photos, reinforcement certificates, and payment receipts related to special container shipping must be kept intact for review by tax authorities.
Professional consultation: Tax regulations are complex and constantly changing. Before undertaking any major planning, be sure to consult a professional tax advisor or accountant to ensure a safe and reliable plan.