Section 404 of the Sarbanes-Oxley Act requires senior management to establish, document, monitor and attest to the effectiveness of their internal controls over financial reporting. This financial reporting requirement has prompted many businesses to intensify the scrutiny of their actual and potential customs and international trade exposures. We can help clients comply with these provisions. We can give management a clear picture, help them identify and fully understand the related customs and international trade risks, and plan strategies to mitigate those risks.
We can assist on a global, regional, or domestic basis. We can focus on specific entities and types of import taxes, as well as countries, or broadened to provide a full and comprehensive customs and international trade review. We can help clients to identify inter alia:
- potential customs and international trade exposures and quantify their impact;
- customs and international trade process inefficiencies; and
- strategies to correct such inefficiencies and assist with implementation.
We can assist CEO’s, CFO’s, and Audit Committees to comply with Section 404 of the Sarbanes-Oxley Act and to uncover risk in the company’s overseas markets, or to affirm the accuracy of provisions and liabilities. Tax directors should not perceive such an assessment as a critique of their performance, but rather, as an opportunity to:
- justify changes in provisions for potential customs exposures;
- identify possible strategies to mitigate and/or eliminate duties and penalties associated with potential customs exposures;
- support an increase in staffing or avoid future workforce reductions;
- develop and implement better customs reporting controls and practices, along with improved customs compliance procedures;
- uncover potential duty refund opportunities;
- gain a comprehensive understanding of the businesses customs and international trade position; and
- obtain a comprehensive understanding of local customs record-retention requirements and uncover any existing deficiencies in corporate record-retention policies.
In engaging Global Customs Compliance, companies can receive a comprehensive analysis of their customs and international trade operations, from the initial recording of each transaction to the completion of local import entry filings and customs returns.
An alternative to your auditors
The Sarbanes-Oxley Act has impacted significantly on non-audit services, such as tax, which auditors can provide to their audit clients. The impact of the Act is highly significant in the large corporate market but businesses in the Middle Market should also be aware of its implications.
It is very likely that you have already held a debate about what your policy will be on the purchase of non-audit services. Clearly, there is a strong case to be made for tax services to be sourced from a non-audit service provider. Global Customs Compliance offers you an alternative to the customs advisory services of your auditors. Key benefits are inter alia:
- Unlikely to require a referral to the Audit Committee;
- No restrictions on value billing;
- No risk of contravening sections 302 and 404 of Sarbanes-Oxley Act.