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ADMINISTRATION OF IMMEX PROGRAM AND PERPETUAL COMPLIANCE

The purpose of this document is to determine the activities that are to be carry on by HPH 
for the project of Administration of IMMEX Program and Perpetual Compliance

The scope is 100% of electronic records1 of import and export pedimentos cleared during
each month, matched against data bases provided by Customs Brokers, purchase and
sales reports, scrap reports and BOMs. The items to review will guarantee that the
information fed into the Immex Software for a proper bacflush are complete and accurate.


The following items will be reviewed for the 100% of operations:


• Declarations of descriptions according to catalogue prepared to customs broker


• Unit cost of each part number.


• Duty


• Type or duty rate applied (FTA, Prosec, Rule 8th, general duty)


• Unit of measure homologation (imports, exports and BOMS must be fed into the
software under the same Unit of Measure)


• Declarations done in text fields of pedimentos


• Consolidated pedimentos closed with the total invoices that should contain. This
includes Virtual Pedimentos.


• Comparisons from quantity of goods reported to inventory through ERP and goods
declared in pedimentos (there may be a variation because of the closing and
beginning of each month but should not be significant)


• Validation that there is a BOM for each finish product.


• Validation that all raw materials, parts and components are included in a BOM.


• Review to additions in value (incrementables) are related to the correct Incoterm
declared in Customs Declarations.


• Warning related to imports declared with a Certificate of Origin.


• Possible manual assignation of bulk items.


• Monthly backflushes.


• Comparison of SAP and Immex Software inventory.


• Validation that goods are imported only under only one tariff code.


• Comparison of date against purchase and sales reports.


• Possible saving in duty founds.

After the monthly Audit to operations is finished, the feeding of the Immex Inventory
Software will be then prepared. Our activities will be the following:


• Preparation of layouts to be transmitted to the IMMEX Inventory software.


• Dummy backflush for preparation of pedimentos code F4 for covering domestic
sales as well as scrap delivery to recycling company.
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• Monthly preparation of backflush.
• Analysis to backflush.


• Comparison to production backflush under the ERP.


• Correction to backflush.
• Feeding of information for F4 pedimentos and scrap treatment.

Validation that all fixed assets coming to Plant have the correct and complete information
related to brand, model and serial number. All fed into the Immex Inventory Software.

Preparation of Annex 30 reports (the transmission is to be done by the Company
since for that purpose the FIEL (that is the password for submitting legal
information to SAT should be kept in the Company´s files) is to be used for the
transmission.
• IMMEX and PROSEC Annual reports

Every month the Company will need to provide us with:


• Data Stage as soon as it is received from SAT (usually within the first 10 days of
the month)


• Bill of Materials

• Customs Brokers Data bases


• Purchase records (accounting reports including, at least, invoice number, date, part
number, quantity, unit of measure, USD value, date, supplier name)


• Sales records (accounting reports including, at least, invoice number, date, part
number, spec, quantity, unit of measure, USD Value, client name, scrap by part
number)


• Inventory to last day of the month from SAP.


• Report from scrap sold to third parties or pick up by recycling companies, including
the part number scraped.

All jobs are under the direct Coordination of a 25 years experienced Senior Partner.
Besides the direct Senior Partner involvement, the operations of a Plant will be assigned to
specific experienced members of HPH for the developing of all described activities. This
will guarantee that the persons in charge of the jobs to be developed are fully immerse in
the practices of the Company.
All reports are filed in standardized layouts and quantified in the exact amount of USD for
each document, line or part number of the electronic reports audited.

If required, the following items must be included in a separate scope.


• Harmonized Tariff Classification issuance. The harmonized tariff classifications are
to be provided by the Company. We will assure that those are correctly declared in
pedimentos and official reports, but HPH will not perform activities for classification
purposes.


• NAFTA of other Free Trade Agreement qualifications. Analysis to Rules of Origin
applicable to components of finished goods.


• The following governmental interactions:
– Lobby with authorities for special permits
– Obtention of rulings.
– Audits from SAT
– Procedimientos Administrativos en materia Aduanera (PAMA)


• Legal defense (Recurso de Revocación, Juicio de Nulidad, Juicio de Amparo)


• OEA and VAT annual recertification.

• Trainee to personnel, however, during the delivery of the Monthly Compliance the
personnel of the Company will be learning as the areas found are to be corrected
directly by the personnel in the Customs area.


• This is a proposal for outsourcing and audit. Not devoted consultant services are
rendered, not trainee to personnel. Questions related to the audit results and
outsourcing are restricted to 3 Partner hours each month.

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