Antidumping Duty Monitoring Program
Astute companies must eliminate uncertainty, manage risks and control liabilities regarding antidumping duties – an area that can be managed. TCS can coordinate an effective AD Monitoring Program that would provide the required tools, expertise and analysis that would enable clients to determine and minimize the AD ultimately assessed after an administrative review.
TCS’s Antidumping Duty Management Program (“AD Monitoring Program”) consists of three primary elements: data extraction and allocations; duty margin analysis; and sales and pricing strategy development.
Data Extraction and Allocations
The first step in the AD Management Program is to review sales and cost allocations and accounting systems to allow clients to compile the necessary data more easily for an AD analysis and potentially reduce reported costs. TCS will:
- Assist in identifying an efficient and accurate process to extract its cost and sales data;
- Review and advise on sales expense and cost allocation methodologies;
- Receive sales and cost data and perform diagnostics on data received. Prepare diagnostic report including any questions, anomalies or inconsistencies and discuss corrective action. Make corrections and adjustments to data or request new data.
Duty Margin Analysis
Once a process is established to extract data on a regular basis, TCS will run the margin calculation to determine the AD liability at a given point in time and then run the margin with current data in established intervals to allow for remedial action on a timely basis. It is only through frequent and regular margin analysis that a client can proactively determine and limit its AD exposure. TCS will:
- Develop margin calculation program in SAS that replicates the program that the DOC will use to determine the margin for the administrative reviews. That program will be tailored to accommodate the client’s circumstances;
- Run preliminary margin analysis and document results by product code, customer, sale month, and comparison type (identical, similar, CV).
Sales and Pricing Strategy Development
TCS will run diagnostic program analysis to determine the products, sales and type of sales that are contributing to the clients AD liability. Once the relevant data is identified, TCS will provide regular reports that may include minimum sales prices for certain products, amongst other data, and strategies to reduce the AD margin