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Authorized Economic Operator
Brazilian Program
June, 2015
Global view
PwC | AEO 3
The Authorized Economic Operator (AEO) is defined by the World Customs Organization (WCO) as “a party involved in the international movement of goods in whatever function that has been approved by or on behalf of a national customs administration as complying with WCO or equivalent supply chain security standards”.
Global view
Authorized Economic Operator
PwC | AEO 4
Global view
Operational AEO Programs
AEO under analysis and/or implementation
Customs Compliance programs
Brazilian Program
PwC | AEO 6
Brazilian Program
The Brazilian Program for Authorized Economic Operators –AEO was set forth by the Federal Revenue’s Normative Instruction n.1,521/2014. The program will certify international trade stakeholders which present low operational risks, concerning both cargo physical security and tax and customs compliance.
Those certified as Authorized Economic Operators may benefit from several operational preferences, including being able to use the AEO seal, which states the company’s reliability before clients and authorities.
The application for an AEO certification is voluntary. Accordingly, not applying for the certification shall not hinder or impose limitations to the stakeholders’ activities regarding international trade.
PwC | AEO 7
Brazilian Program
Mo
da
liti
es
1
AEO-Security (AEO-S): international trade stakeholders’ certification based on security criteria applied to the logistics chain, following the requirements set forth by the Brazilian Federal Revenue and the World Customs Organization (WCO).
AEO-Compliance (AEO-C): international trade stakeholders’ certification based on the compliance with tax and customs obligations.
2
AEO-Full (AEO-F): certification comprising both AEO-S and AEO-C. 3
Implementation timeline
PwC | AEO 9
Implementation timeline
December/2014 December/2015 December/2016
Implementation of AEO-S, focusing on the certification of
the stakeholder involved in the
export flow.
Implementation of AEO-C, focusing on the certification of
the stakeholder involved in the
import flow, and, therefore,
implementing AEO-F.
Integrating the Brazilian Program of AEO with other State agencies, e.g. authorizing agents, in order to simplify and integrate the
international trade procedures.
Benefits
PwC | AEO 11
Benefits
i. Reduction in the percentage of cargo selected for conference channels and priority processing in export procedures;
ii. Priority in certification for the programs Phase 2;
iii. Waiving of the warranty required for Customs Transit Special Customs Regime;
iv. Waiving of requirements already fulfilled in AEO application for special customs regime application purposes; e
v. Participation in the AEO Forum, trainings and seminars for improving AEO Brazilian Program.
i. Benefiting from Mutual Recognition Agreements (MRA);
ii. Exclusive communication channel with the Brazilian Federal Revenue;
iii. Improvement of the company’s image and reputation as an AEO; e
iv. Simplification and integration of customs procedures regarding security and control.
Pr
og
ra
m’s
be
ne
fits
AE
O-S
’ b
en
efi
ts
Eligibility and admissibility requirements
PwC | AEO 13
Eligibility and admissibility requirements
Are eligible to the Brazilian AEO program the following stakeholders*:
Freight Forwarder Customs Broker Transporter
Port’s or airport’s operator
The depositary of goods under customs control
Importer or exporter
* The aforementioned list may be expanded by the Brazilian Administrative Customs Coordination (COANA).
PwC | AEO 14
Eligibility and admissibility requirements
Are eligible the stakeholders which fulfill the following requirements: History of compliance with customs
legislation.
Computerized system for commercial, accounting, financial and operational management.
Financial soundness in order to maintain and improve logistics chain security.
Policies setting forth regular internal control audits.
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PwC | AEO 15
Eligibility and admissibility requirements
Additionally, the authorities also require from AEO-S’ applicants:
Commercial partners who adopt the security criteria required regarding the logistics chain.
Cargo unit control.
Access controls.
Human Resourses policies.
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Security procedures.
Security and threat awareness trainings.
Physical security of the facilities.
Information Technology.
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PwC | AEO 16
Eligibility and admissibility requirements
In combination with the eligibility requirements, the company shall also comply with the admissibility requirements regarding the certification procedure, as follows:
Electronic Tax
Domicile
Electronic Account Records
Corporate Taxpayer
Number with more than 2
years
Being an eligible
stakeholder for more than 2
years.
Certified tax regularity
3 years as a certified customs
broker, if applicable
Issuance of Electronic Transport
Bill (CT-e), if applicable
Formal Request
(electronic)
Absence of denied
applications in the last 6 months
Certification steps
PwC | AEO 18
Certification steps
The procedures to apply for an AEO certification include the following sequential steps:
Self-assessment Questionnaire
Mantainance and Monitoring
Formal Request *
Assessment of admissibility
requirements.
Compliance assessment
Certification
The AEOs shall be subject to monitoring concerning the maintenance of the requirements and criteria for certification as well as a reviewing procedures in under 5 years.
Issuance of the AEO Certificate in recognition of the Customs-Company partnership. The certificate has not determined deadlines and shall comprise the headquarters and branches.
Assessment of compliance with the specific and general requirements of eligibility and safety of the logistics chain (90 days, extendable for equal period.
Certification AEO
Completion of the self-assessment questionnaire, and documentation to support
the answers.
Formal application request comprising the
aforementioned, questionnaire, supporting
documentation, among others.
Consists of an assessment of the company’s compliance
with the mandatory requirements from article 8,
mostly concerning the observance of tax and customs obligations.
* A Federal Revenue may request further information and documents, which shall be summited within 30 days from the notification.
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PwC | AEO 19
Certification steps
Self-assessment questionnaire
General information
Eligibility requirements
Security requirements
9 questions mostly regarding the company’s activities, structure and records.
10 questions which verify if the company fulfills all the eligibility requirements.
33 questions regarding the company’s supply chain structure and security measures in force.
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AEO and Blue Line
PwC | AEO 21
AEO and Blue Line
AEO Blue Line
Applicable to different stakeholders of international trade, regardless of the number of transactions performed or equity;
The application consists of the self-assessment questionnaire and supporting documentation, without the mandatory presence of a audit company;
The evaluated criteria comprises the general record and structure information, eligibility requirements and security of the supply chain; and
Should be renewed every 5 years.
Applicable only to importer and exporter with equity equal or superior to BRL 10,000,000.00 and high number of transactions performed;
The application requires an audit report based on the standards set forth by the Federal Revenue;
The evaluated criteria comprises the company’s corporate information and structure, accounting records, international trade aspects (transactions, amendments, special customs regimes, etc.) and security of the supply chain; and
Should be renewed every 3 years.
Our methodology
PwC | AEO 23
Our methodology
Our methodology
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PwC | AEO 24
Our methodology – AEO Presentation
The client Companies which are aware of being not compliant with the AEO requirements.
Objective Provide cliente with AEO information.
Approach
Complete mapping of the company’s structure and comparison with the requirements set by the AEO legislation. After the review, PwC, along with the client’s management, will prepare an action plan for the company’s compliance with the aforementioned requirements.
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3 4
PwC | AEO 25
Our methodology – Pre-Diagnosis
The client
Clients which intend to apply for the AEO certification, but wish to verify if the company is compliant with the main requirements of the program.
Objective Verifying in a shorter time and at lower cost if cliente complies with the main requirements to avoid denied applications.
Approach Mapping of the company’s main structure and comparison with the most critical requirements set by the AEO legislation.
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3 4
PwC | AEO 26
Our methodology – Complete Review
The client Clients which intend to apply for the AEO certification and are aware of its compliance with the requirements.
Objective Prepare answers to the questionnarie and analyze the support documents
Approach
Complete mapping of the company’s structure and comparison with the requirements set by the AEO legislation. After the review, PwC will issue the report with the results of our analisys.
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PwC | AEO 27
Our methodology - Certification
The client Clients which are applying for AEO certification.
Objective Assisting the company with the AEO certification process.
Approach
Assisting the company in the completion of the self-assessment questionnaire and in the preparation of the supporting documentation. Preparing the electronic files in accordance with the procedures set forth by the Federal Revenue, summiting the application and follow-up of the process.
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PwC | AEO 28
Our methodology
Steering committee
Management
Execution
PwC Client
Tax Partner Customs and International Trade
Director Advisory Partner
Directors
Customs and International Trade Manager
Advisory Manager Facilitators
Customs and International Trade Manager
Senior consultant
Our professionals
PwC | AEO 30
Tax Partner Telephone: 3674-3747 [email protected]
Customs and International Trade Director Telephone: 3674-3553 [email protected]
Lucimara Santos
Daniel Maia
Our professionals
© 2013 PricewaterhouseCoopers Contadores Públicos Ltda. Todos os direitos reservados. Neste documento, “PwC” refere-se à PricewaterhouseCoopers
Contadores Públicos Ltda., a qual é uma firma membro do network da PricewaterhouseCoopers, sendo que cada firma membro constitui-se em uma
pessoa jurídica totalmente separada e independente.
O termo “PwC” refere-se à rede (network) de firmas membro da PricewaterhouseCoopers International Limited (PwCIL) ou, conforme o contexto
determina, a cada uma das firmas membro participantes da rede da PwC. Cada firma membro da rede constitui uma pessoa jurídica separada e
independente e que não atua como agente da PwCIL nem de qualquer outra firma membro. A PwCIL não presta serviços a clientes. A PwCIL não é
responsável ou se obriga pelos atos ou omissões de qualquer de suas firmas membro, tampouco controla o julgamento profissional das referidas firmas
ou pode obrigá-las de qualquer forma. Nenhuma firma membro é responsável pelos atos ou omissões de outra firma membro, nem controla o julgamento
profissional de outra firma membro ou da PwCIL, nem pode obrigá-las de qualquer forma.