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HMRC internal manual

Guidance on the Audit of Customs Values

Case Studies: importations by a selling agent


A third country manufacturer supplies paper on reels to EU buyers through an EU selling agent. The manufacturer and selling agent, although separate legal entities, are subsidiaries in the same group. The goods are entered to free circulation by the selling agent and subsequently stored at their premises before sale.

The agent negotiates duty-inclusive prices with unrelated customers, which are invariably accepted by the manufacturer without question. The agent issues invoices and receives payment from customers.

The proceeds of sales are remitted to the manufacturer after deducting:

  • the costs of discharge from the ship
  • a commission of 2%
  • the costs of delivery to the agent’s premises
  • the cost of storage at the agent’s premises
  • the cost of delivery to the customer and
  • the customs duties and other taxes payable in the EU.

There are no similar or identical goods for comparison


As the customs value cannot be determined under Methods 1, 2 or 3, then Method 4 is appropriate.

All the elements shown above can be deducted under Article 142 of the IA as follows:

  • 142 commission and storage
  • 142 discharge, delivery to the agent and to the customer and
  • 142 customs duties and other taxes.