ARE YOU READY FOR POST-CLEARANCE AUDIT WITH GGM?
What Is a Post-Clearance Audit?
Post-Clearance Audit is an audit process carried out within the scope of Articles 10 and 73 of Customs Law No. 4458 and the Regulation on Post-Clearance Audit and the Control of Risky Transactions issued based on these articles, in which companies’ customs procedures are reviewed retrospectively.
The purpose of these audits is to determine whether companies have fulfilled their obligations accurately and completely within the framework of customs legislation and other relevant regulations in relation to customs duties.
Post-clearance audit is not limited to taxes only; it also constitutes a comprehensive audit covering many areas such as:
- origin and valuation procedures,
- permits and documents,
- accounting records,
- production and supply processes,
- compliance with customs regimes
It may be conducted at the company’s headquarters or at any location where it operates (including free zones).
How Does the Post-Clearance Audit Process Begin?
Post-clearance audits are carried out in a planned and systematic manner by the central inspection officers of the Ministry of Trade. Official notification is served to the company at least 15 days before the audit begins.
This notification specifies in detail:
- the officers who will conduct the audit,
- the period to be reviewed,
- the audit start date,
- the rights and obligations of the company,
- the information and documents that must be prepared before the audit
When deemed necessary, post-clearance audits may also be conducted outside the annual audit plan.
Rights of Companies
Companies subject to post-clearance audit may:
- request that the audit be conducted during working hours,
- personally attend the audit or appoint a representative,
- request a final meeting,
- review the evaluation report in advance and provide their opinion,
- request the recusal of audit officers for valid reasons,
- request information regarding the matters identified during the audit.
In addition, if a justified and acceptable reason is presented, the audit start date may exceptionally be postponed.
Obligations of Companies
Companies are obliged to:
- submit all information, documents, and records requested within the scope of the audit in full,
- provide the necessary support regarding access to electronic systems,
- provide an appropriate working environment,
- allow inspections in all areas of the workplace,
- retain commercial records and documents for the legally required periods
Preparation Before a Post-Clearance Audit
In order for the audit process to proceed quickly and smoothly, companies are generally requested to provide:
- import and export files for the review period,
- overseas supplier agreements,
- financial statements and accounting records,
- VAT returns,
- payment documents and bank records,
- stock, production, and sales account statements
Importance of Post-Clearance Audit
Errors and deficiencies that may be identified during post-clearance audits may lead to:
- high-value tax differences,
- retroactive penalties,
- sanctions that create smuggling risk
For this reason, it is of great importance that companies carry out their customs and foreign trade processes in compliance with legislation and in an auditable manner from the very beginning.
Post-Clearance Audit Results and Risk Score
At the end of the audit, evaluation and administrative reports are prepared. Based on these reports, companies are assigned a risk score:
- Low risk: Faster procedures with less control
- Medium risk: Standard control procedures
- High risk: Frequent and detailed audits
The risk score directly affects the speed of the company’s future customs procedures and the frequency of inspections.
Our Post-Clearance Audit Consultancy
In order to ensure that companies are prepared before facing post-clearance audits or can properly manage ongoing audit processes, we provide:
- pre-audit review and risk analysis,
- document and process compliance audits,
- professional support during the audit process,
- solution and improvement recommendations regarding findings
