Virtual Warehouse – Inland Customs Warehouse

Virtual Warehouse – Inland Customs Warehouse

The regime allows companies to deposit their merchandise at warehouses under control by tax authorities and enjoying the suspension of taxes.

The regime allows companies to deposit their merchandise at warehouses under ...

The purpose of the Inland Special Customs Warehouse Regime (Regulatory Instruction IN 241) allows importing and exporting companies to deposit their goods in bonded warehouses under control by tax authorities and enjoying the suspension of taxes. This legal order was set forth by Administrative Order No. 3,518 issued on September 30, 2011 and by Executive Regulatory Act, issued by Coana - Customs Administration General Coordination/Cotec - IT General Coordination No. 2 on September 26, 2003.

This Regime has two main types: EADI Exporter, which is subdivided into EADI Ordinary Exporter, aimed at companies from all economic segments that export goods, and also the EADI Extraordinary Exporter, aimed at trading companies. The other type is EADI Importer, which comprises all sorts of companies that need input and make imports.

This is a Customs Regime that allows operations together with other regimes, such as Drawback, RECOF and DAC (Certified Bonded Warehouse).

The Special Customs Depot Regime for Imports allows the storage of foreign merchandise in a bonded warehouse publicly used, and federal taxes, PIS/PASEP - Import and COFINS - Import charged on imports are suspended. Merchandise qualified for the Customs Depot Regime for Imports and Exports may be:

  • Displayed, and shown to work and tested to check whether they work.
  • Processed.
  • Have their tags maintained or repaired to meet the requirements of foreign buyers.

Benefits granted under the Inland Customs Warehouse Regime are the following:

  • The Inland Customs Warehouse Regime for imports allows the storage of merchandise at bonded warehouses, and applicable taxes are suspended.
  • The Inland Customs Warehouse Regime for exports allows the storage of merchandise at a bonded warehouse:
    I - under the common regime: with suspension of applicable taxes.
    II - under the special regime: enjoying the right to use the tax benefits granted as export incentives, before their actual shipment abroad.

The requirements set for companies to qualify for the regime consist of: 

  • Registering the bonded warehouse within the Brazilian Federal Revenue Service.
  • Developing an automated control system over the inflow, movement, storage and outflow of merchandise held by the regime's beneficiaries. 
  • Each beneficiary should create an isolated area inside the bonded warehouse to carry out the transactions allowed by the regime. 
  • Posting official reports on the web for inspection by the Brazilian Federal Revenue Service.
  • The beneficiaries of the Inland Customs Warehouse Regime for exports must meet the following requirements:
    I - under the common regime: the legal entity that deposits merchandise to be shipped to foreign markets in an accredited warehouse.
    II - under the special regime: only the exporter.

Commitments made by the beneficiary to remain under the regime:

The merchandise can remain under the Inland Customs Warehouse Regime for exports for:
I - under the common regime: one year, which may be extended for not more than two years.
II - under the special regime: 180 days.

During the effective period the beneficiary must take one of the following actions with respect to the bonded merchandise:

  • Start the export customs clearance.
  • Under the regime, add the merchandise back to the establishment's inventory.
  • In any other case, pay suspended taxes and reimburse tax benefits enjoyed when the merchandise was qualified for the Regime.

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