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1、Trade,Tariffs and More 8 April 2025PwCPwC Speakers todayJohn OLoughlin,Partner,Global Trade and C087 653 3989Peter Reilly,Partner,Tax Policy L087 372 0882Colm OCallaghan,Partner,PwC P087 7761711PwC01Global Trade&CustomsPwCIntroduction When Products cross bordersManufacturerShipperCustoms ClearanceIm

2、porter Releases finished goods from factory Issues invoice and packing list to Buyer/Importer Goods move via inland freight to port of exportGoods loaded onto ship/plane/truckBill of lading issuedGoods leave country of exportEntry document package includes:entry declaration form,commercial invoice,p

3、acking list,and bill of ladingAdditional documents may include FTA certificates,import licence(e.g.FDA regulated products),and other misc.documentsDeclares goods to customs authoritiesReceives goods into inventory and onward sells goods to customersFor every export,there is a subsequent importPwCGen

4、eral Principles of EU Customs Imports&ExportsEUImportant ConsiderationsShipments to the EU from third countries are subject to import formalities.Shipments from the EU to third countries are subject to export formalities.Customs formalities include presentation of a customs declaration,relevant supp

5、orting documentation and other misc.requirements.The EU is a customs union,which means that no borders exist within the EU for customs purposes.Therefore,any movements of goods intra-EU(i.e.from one EU country to another)are not subject to customs formalities.PwCCustoms Duty DriversClassificationOri

6、ginValuationTariffValueCustoms LegislationCustoms DutiesDutiesCustoms ValueDutiesTaxable Basis for VATPwC02Trump TariffsPwCIn the news this weekPwCBackground to US TariffsActual outcomesDetails2017 Policy MeasuresThe United States-Mexico-Canada Agreement(USMCA)entered into force on July 1,2020 as a

7、substitute to NAFTAProposal to explore alternatives for the North American Free Trade Agreement(NAFTA)Renegotiate Trade AgreementsTariffs of up to 25%were imposed on Chinese goods,along with 25%tariffs on steel and 10%tariffs on aluminum from various countries,including the European UnionImplement t

8、ariffs on imports into the USImpose TariffsWhile the tariffs on China did reduce imports from China,these were largely offset by increased imports from other countries,leading to a$916 billion trade deficit in goods,marking an increase of approximately 21%from 2016Decrease the US trade deficit by pr

9、omoting US exports and reducing importsReduce Trade DeficitDuring President Trumps first term(20 January 2017 to 20 January 2021),his administrations trade policy and use of tariffs marked a significant shift in the US approach to international trade.Details2025 Policy MeasuresReview of US trade pra

10、ctices and policies with a view to reducing the US trade deficit/US trade relations with ChinaAmerica First Trade PolicyImplement both blanket and sectoral tariffs on inbound goods entering the US China/Mexico/Canada tariffs Implementation of TariffsReview tariff imposed on US goods by 3rd countries

11、 and impose measures to level the difference between rates Reciprocal Tariff PlanPresident Trumps second term has significantly focused on the use of tariffs and trade policy as a measure to affect change in other countries.PwCUS Tariffs Recent Position United States Trump Tariffs Recent executive o

12、rders have impacted tariffs,with some temporarily postponed.Below is the current tariff landscape:China-origin goods:20%tariff,in addition to existing rates(which can be up to 50%on certain goods and 100%on electric vehicles).Mexico&Canada USMCA qualifying:25%tariff delayed indefinately Mexico&Canad

13、a origin but not USMCA qualifying:effective as March 4 Steel&Aluminum:25%tariff on covered imports from all countries(except Russian aluminum at 200%)effective March 12.Motor Cars:25%tariff on covered imports from all countries(some exception for Mexico and Canada)effective April 3.De minimis will b

14、e eliminated for goods subject to IEEPA tariffs(and possibly all goods subject to Sec.301,Sec.232,or Sec.201)when systems required become operational America First Trade Policy(Jan 20,2025)-Investigation of Unfair and Unbalanced Trade deficit(Sec.2a)focus on countries with annual trade deficits in g

15、oodscould be targets for specific countrytariffs -Investigation of Unfair Trade Practices(Sec.2c)could involve a myriad of options of executive orders/executive actions on tariffs-Consultation/Review of USMCA(Sec.2d)could speed up negotiations of USMCA prior to the July 2026 review-PNTRwith China(3d

16、)request for proposed changes tonormal trade relations with PRC-Investigations to be concluded by April 1 Reciprocal Trade and Tariff Order(Feb 13,2025)-Fair and Reciprocal Plan(FARP)(Sec.2)investigation on non-reciprocal trade relationships with the US(to include VAT)-Taking Action(Sec.3)within 180

17、 days(Aug.12 2025)PwC“Liberation Day”Reciprocal TariffsMinimum base level 10%tariffon all countries.This will take effect April 5,2025Individualized reciprocal higher tariff on the countries with which the United States has the largest trade deficits.This will take effect April 9,2025All other count

18、ries will continue to be subject to the original 10%tariff baseline.Tariffs will remain in effect until such a time as President Trump determines that the threat posed by the trade deficit and underlying nonreciprocal treatment is satisfied,resolved,or mitigated.IEEPA Order also contains modificatio

19、n authority,allowing the increase of tariffs if trading partners retaliate or decrease the tariffs if trading partners take significant steps to remedy non-reciprocal trade arrangements.Goods Exempt From Reciprocal TariffsSteel/aluminium articles already subject to Section 232 tariffsCars/car parts

20、already subject to Section 232 tariffsCopperPharmaceuticals*SemiconductorsLumber articlesAll articles that may become subject to future Section 232 tariffsBullionEnergy and other certain minerals that are not available in the USArticles subject to 50 USC 1702(b)(Communications,Donations,Informationa

21、l Materials)*Medical devices are not contained within the list and therefore will be subject to the additional tariffsPwCReciprocal Tariffs*Key MarketsRateCountryRateCountry49%Cambodia34%China30%South Africa20%European Union37%Bangladesh31%Switzerland10%Singapore10%United Kingdom 17%Israel24%Japan17

22、%Philippines10%Brazil10%Chile46%Vietnam10%Australia32%Taiwan29%Pakistan26%India10%Turkey25%South Korea44%Sri Lanka36%Thailand10%Colombia32%Indonesia*This list is not exhaustivePwCEU Countermeasures&CommentaryEU Retaliatory MeasuresEU Retaliatory MeasuresOn March 12th,the EU Commission announced coun

23、termeasures in response to the US tariffs on steel and aluminium products,which they deemed“unjustified”.The tariffs which will be imposed range from 10%to 75%with the majority of products falling within the 25%category.Following a period of consultation,the EU has postponed the implementation of th

24、ese measures until 15 April with a vote taking place on 9 April.Following Trumps announcement,the EUs main priority is to negotiate however EU trade commissioner Maro efovi has shared“until now,despite of efforts we havent seen the real engagement which would lead to the mutually acceptable solution

25、”from the US side”On 15 April,it is believed the EU will publishe the first category/list of products which will be subject to duty.The remaining duties will be introduced on the 15 May.Some news sources are specifying most tariffs will take effect 16 May,while other duties will be introduced in Dec

26、ember.This remains to be confirmed.Ursula Von der Leyen“We stand ready to negotiate with the US.Indeed,we have offered zero-for-zero tariffs for industrial goods as we have successfully done with many other trading partners.Because Europe is always ready for a good deal.So we keep it on the table.Bu

27、t we are also prepared to respond through countermeasures and defend our interests.”PwCTariff Mitigation Strategies Where tariffs are in place,certain strategies can be employed to minimise/reduce their impact.ConsiderationsDetailUS Mitigation StrategyRecent US trade policies have prevented the use

28、of this strategy Allows for a refund of duty on products which have been re-exported from the US Duty DrawbackSet up costs/timeEntering goods under a bonded warehouse/FTZ deferring the duty payment until such a time as they are released to free circulationBonded warehouseMust be a bona-fide sale Cus

29、toms valuation methodology to use the first sale within a chain of sales lowering the tax base on which tariffs are appliedFirst sale valuationMust have a legal basis for using an alternative value Consider using other methods of valuation(where allowable)to reduce customs valueAlternative valuation

30、Availability of materials/quality of materials Shift sourcing location to benefit from reduced duty rate in comparison with current locationOrigin shiftingOrigin determination may not be favourableReview non-preferential origin rules to ensure origin determination is correct FTA/Origin complianceBla

31、nket tariffs make this irrelevant Review classification of products to ensure they are not captured by a tariff measure incorrectly Tariff classificationConsiderationsDetailEU Mitigation StrategyIntensive tracking and reporting,set up costs/timeNon-Union goods brought into the EU for further process

32、ing e.g.raw materials imported for processing into a finished productInward ProcessingIntensive tracking and reportingEU goods can be temporarily exported for processing or repair in another territory,and re-imported with duty reliefOutward ProcessingAuthorisation requirementsNon-Union goods can be

33、stored in a customs warehouse with duty suspended until released into free circulation.If goods are re-exported,duty remains suspendedCustoms WarehousingMust have method for tracking individual productsUnion goods can be re-imported into the EU without payment of duty or VAT.Returned Goods ReliefPwC

34、Tariff Impacts Understanding which tariffs applyWhere are my raw materials from?Are there multiple manufacturing locations?Where is labelling or packaging conducted?Are repairs or maintenance involved?The rules of origin are key to understanding which tariff applies to your goods on import into the

35、USA flow of goods can occur through multiple countries,but a product can only have one country of origin The country of origin is generally-not always-the country of manufacture Non-preferential origin is critical whereby the US applies the substantial transformation criterion:“an article that consi

36、sts in whole or in part of materials from more than one country is a product of the last country in which it has been substantially transformed into a new and different article of commerce with a name,character,and use distinct from that of the article or articles from which is was so transformed”Co

37、untry of origin of finished productSubstantial Transformation considerationsPwCFirst Sale ValuationFirst Sale for Export(“FSFE”or“First Sale”)is a US customs valuation concept that can result in significant duty savings for companies importing dutiable merchandise using multi-tiered supply chain Und

38、er FSFE methodology,the basis for all customs assessments(i.e.,duties,tariffs,fees,etc.)can be founded on an earlier manufacturer-to-middleman arms length price,which is typically lower than the middleman to importers price.FSFE can be leveraged for any products,in any industry,even where products a

39、re subject to additional tariffs such as Section 301 and Section 232 tariffs.How to use it Companies currently importing goods into the United States through a multi-tiered transaction structure should consider using the First Sale for Export valuation method to reduce duties/tariff impacts.Companie

40、s currently not importing goods into the United States through a multi-tiered transaction structure may wish to explore the feasibility to modify their supply chains to accommodate an FSFE structure.Ideas to consider Reduce duty/tariff exposure,especially in cases where the middlemans non-product co

41、ntributions are significant Decrease supply chain costs without sacrificing product quality or squeezing suppliers for pricing reductions Achieve duty/tariff mitigation without disturbing tax/transfer pricing characterizations of transactions and avoid TP adjustment reporting requirements.Obtain ref

42、unds on previous years importations if those transactions satisfied FSFE requirementsWhat value can you realize?PwCFSFE Process MapEntity 2Entity 1Second Sale Value(Current Customs Value)Current Customs Value includes:First Sale Value plus:Middleman Mark-up Middleman Costs And possibly others:E.g.,I

43、ntellectual Property RightsFirst Sale Value FSFE Price generally includes:Raw Materials Labour Foreign manufacturers margin Foreign manufacturers overhead Other costs and expenses20%Mark-up20%Duty Rate*Duty Savings=$4,000First Sale(Invoice 1)Second Sale(Invoice 2)NewCoPurchase Order 2Purchase Order

44、1Ex-Factory Price:$80,000Duty=$16,000*FOB Price:$100,000Duty=$20,000PwCKey impact levers to reduce tariff exposure Supplier/Customer Pricing and NegotiationsTrade Policy Consulting&Customer MessagingFirst Sale/Country of Origin/Free Trade Agreements AlternativeValuation Duty Drawback(5-year retro op

45、p)Supply Chain Footprint change or diversifyProduct Flows/Alternative materialsTariff Classification/Exclusions or Exemptions Free Trade Zones(FTZ)ExistingSupply ChainModified Supply ChainStockpile inventorySupplier Negotiations lock in costsSite selectionPwC03Supply Chain ExamplesPwCTariff Impact:E

46、xample 1-what tariffs apply?1:A steel article is manufactured in the US:A.Finished article(steel)is manufactured in the US.B.Finished article is sold to distributor in the EUC.Sold to a customer in Canada.D.Customer returns the article to the US following end of contract.USACAEUA.Country of Manufact

47、ureB.Sold to Distributor in EUC.Sold to Customer in CanadaD.Return to the USPwCTariff Impact:Example B-what tariffs apply?2:Protein bars are manufactured and sold to consumers in the US via retail outletsA.Certain raw materials(whey,cocoa powder,sugar)is sourced from China B.Other raw materials(palm

48、 oil,raising agents)is sourced from IndiaC.The materials are used to manufacture protein bars in Germany.Packaging is also performed in GermanyD.The finished products are exported to US retail shops,to be sold to consumersCNINDEUSPwC04Tax PolicyKD0Slide 22KD0 Peter Reilly(IE)-Hi Peter,please see the

49、 following section for Tax Policy slides to be included for the Enterprise Ireland webinar tomorrowKathy Doyle(IE),2025-04-07T14:24:39.4520 0 Thanks,I actually dont plan to use slides so will just talk to this place holderPeter Reilly(IE),2025-04-07T14:43:24.393KD0 1 Thanks PeterKathy Doyle(IE),2025

50、-04-07T15:15:23.625PwC05What this means for businessesPwCWhat this means for EU businessesMarket ShiftsHigher tariffs on European exports could reduce their competitiveness in the US market.This may lead to a decline in market share for European companies.European businesses might need to explore ne

51、w markets or strengthen existing ones.US companies might replace European imports with domestic alternatives,changing market dynamics.Supply Chain Disruptions Broad tariffs on European goods could disrupt supply chains.This may lead to higher costs and delays.European companies might need new suppli

52、ers or logistics strategies.Tariff uncertainty could deter investment in cross-border infrastructure.0101Economic UncertaintyUnpredictable trade policies under a Trump administration could create economic uncertainty.This may deter investment and slow economic growth.Businesses could face challenges

53、 in long-term planning due to fluctuating trade regulations and potential retaliatory actions.Uncertainty could impact consumer confidence and spending patterns.Tariff RetaliationThe EU is likely to respond to US tariffs with retaliatory measures on key American exports.This could lead to a broader

54、trade conflict,affecting many industries in both the EU and the US.Resulting trade barriers could increase costs for businesses and consumers.Economic relations could be further strained.030304040202What does this mean in practice?Broad tariffs on European goods,such as a 25%tariff on cars,could dis

55、rupt supply chains,leading to higher costs and delaysEuropean companies might need new suppliers or logistics strategies,and tariff uncertainty could deter investment.Higher tariffs would reduce European exports competitiveness,potentially decreasing their market share in the US.The EU might retalia

56、te with tariffs on American exports,escalating trade conflicts and increasing costs for businesses and consumers.0505PwCDecisive actions to address Supply Chain uncertainties posed by tariffsTo navigate the impact of changing tariffs on supply chains,the following key actions can be taken:Diversify

57、supply chainsExplore alternative markets and diversify supply chain strategies to minimize risks associated with emerging trade tariffsRedesign network strategiesReevaluate and redesign supply chain networks to ensure greater control and visibility to adapt quickly to emerging trade barriersEnhance

58、operation efficiencyImprove operational efficiency and cost management to streamline operations and reduce costsInvest in advanced technologiesAdopt innovative planning solutions and tools to increase supply chain visibility and predictive capabilities to anticipate challenges and respond proactivel

59、y12340Scenario PlanningAssess the impact of the tariffs to your business in the short,medium and long term.Scenario plan for a variety of outcomes.PwCCost Inflation ImpactValue AddingCostMarginThe increase driven by the factors below:Tariffs will apply to both EU imports and exports with the US appl

60、icable to both raw materials and finished productsSupply chain lead times will become longer driving logistics costs,and supply chain structures may need to be reconsideredPrice increases will need to be absorbed within the business or passed on to the customerGreatest impact will be on multinationa

61、l suppliers due to higher tariffs on finished goods.Supply ChainPrimeCostLanded CostCOGS INCREASEPre-additional TariffsTariffs on raw materials will apply and drive cost increasesIncreased logistics costs driven by longer lead times and need for additional stock holding,as well as costs associated w

62、ith potential supply chain restructuringThree additional costs:1.Custom duties working capital implications2.Custom administration charges3.Tariffs on finished goodsThe ChallengeTariffs are expected to add additional cost throughout all stages of the value chain.Additional costs driven by imported r

63、aw materials and finished goodsPost-additional TariffsPwCJohn OLoughlinPartnerLPaul RodgersDirectorEI-Point of CMark BrennanDNick KoolenDDavid LusbySenior MKathy DoyleMAlicia SuarezMBen TwomeyMJonathan BurkeMThe PwC Global Trade and Customs Team is the largest customs advisory team in Ireland with 1

64、9 members from a variety of backgrounds.We provide a wide range of customs,excise and export control advisory services to importers and exporters who operate global supply chains.The team provides clients with practical,commercial advice to support their compliance with customs and trade requirement

65、s and to help them to minimise duties and other costs associated with cross border trade.We support both domestic and multinational clients across multiple industries(including Agri-food,Pharmaceuticals&Medical Devices,Technology,Retail and Consumer Products,Industrial Manufacturing and Public Secto

66、r)and use our understanding of sector-specific issues to tailor our advice to client needs.The team itself prides itself on keeping up-to-date with customs and trade developments and on providing advice that is relevant,insightful and commercial.Global Trade&Customs -Meet the team Thank you 2025 PwC.All rights reserved.PwC refers to the PwC network and/or one or more of its member firms,each of which is a separate legal entity.Please see for further details.This content is for general information purposes only and should not be used as a substitute for consultation with professional advisors.