

Turkish Customs questions or rejects the invoice price of imported goods. Learn which payment, contract, accounting, pricing, transport and comparable-sale evidence importers should submit to defend the declared customs value.
When Turkish Customs considers the declared invoice price unusually low, the importer may face a customs valuation investigation, additional tax assessment and potentially administrative penalties.
A common situation is:
Supplier invoice: USD 100,000
Customs position: Comparable goods appear to be worth USD 160,000
The importer should not respond merely by saying:
“The invoice is genuine.”
The objective is to demonstrate that the declared price reflects the genuine commercial transaction and that the relevant customs-value rules support its use.
Under Turkey’s customs valuation framework, the transaction-value method is examined first. The Ministry of Trade states that the customs value is determined through six methods applied sequentially: transaction value, transaction value of identical goods, transaction value of similar goods, deductive value, computed value and the fall-back method. A later method should not be used where customs value can properly be determined under an earlier one.
The importer should reconstruct the transaction from beginning to end:
Purchase negotiation
→ purchase order
→ sales contract
→ invoice
→ payment
→ shipment
→ customs declaration
→ accounting entry.
The stronger the documentary chain, the easier it is to demonstrate that the invoice reflects a genuine transaction.
The invoice is the starting point, but it should not be the only evidence.
Check whether it clearly identifies:
Any inconsistency should be explained immediately.
A signed supply agreement can be extremely important.
It may establish:
The contract helps Customs understand why the price is commercially reasonable.
Where no comprehensive master agreement exists, provide:
These documents can demonstrate that the price was agreed before Customs questioned the shipment.
One of the strongest forms of evidence is proof that the importer actually paid the invoiced amount.
Submit relevant:
The Ministry defines the price actually paid or payable broadly as the total payment made or to be made by the buyer to the seller, or for the seller’s benefit, in connection with the imported goods.
Customs may become suspicious if:
Invoice: USD 100,000
but
Bank transfer: USD 125,000.
The importer should explain the difference.
The additional amount might relate to:
Prepare a payment reconciliation rather than leaving Customs to infer the reason.
Many international transactions involve:
30% advance
and
70% after shipment.
Provide evidence of both payments and connect them to the relevant invoice.
A single bank transfer showing only part of the price can otherwise create unnecessary questions.
A company may pay several invoices through one transfer.
Prepare a reconciliation table:
| Invoice | Invoice Amount | Payment Reference | Allocated Amount |
|---|---|---|---|
| Invoice A | USD 40,000 | Transfer 101 | USD 40,000 |
| Invoice B | USD 35,000 | Transfer 101 | USD 35,000 |
| Invoice C | USD 25,000 | Transfer 101 | USD 25,000 |
This creates a transparent audit trail.
Internal accounting evidence can support the commercial reality of the transaction.
Relevant records may include:
The accounting records should correspond with the invoice and payment documents.
A lower price is not automatically a false price.
Commercial reasons may include:
The explanation should be supported by documents.
Suppose Customs compares:
10 units purchased by another importer
with
10,000 units purchased by your company.
The prices may legitimately differ.
Provide:
A supplier may offer a strategic customer significantly lower prices than occasional purchasers.
Provide historical invoices showing the pricing relationship over time.
Consistency can strengthen credibility.
Older inventory may legitimately sell below the supplier’s ordinary price.
Evidence may include:
Customs may compare the imported goods with products that appear identical but actually differ.
Compare:
Comparable valuation evidence should involve genuinely comparable goods.
A manufacturer selling directly to a major distributor may offer a different price from a sale to:
The Ministry’s current valuation guidance expressly recognizes commercial-level and quantity differences when comparable values are examined.
A supplier’s catalogue may show a list price of USD 1,000 while the importer paid USD 700.
That is not necessarily problematic.
Explain:
List price
versus
actual wholesale price
versus
negotiated contract price.
Emails exchanged before the purchase can be highly persuasive.
For example:
Supplier initially offers USD 900 per unit
→ Importer negotiates volume commitment
→ Supplier agrees to USD 700
→ Contract and invoice use USD 700.
This provides a commercially logical explanation for the final price.
Customs may scrutinize transactions between:
However, the existence of a relationship does not by itself require rejection of the transaction value.
The Ministry expressly states that the existence of a buyer-seller relationship alone is insufficient to reject the transaction value. The relevant question is whether that relationship affected the price.
Evidence may include:
The objective is to demonstrate that the price remains commercially supportable.
For related-party transactions, official guidance recognizes comparisons with qualifying values involving identical or similar goods and other specified valuation benchmarks. Appropriate differences in commercial level, quantity and relevant costs should be considered.
Therefore, a superficial comparison with one unrelated import may not be sufficient.
The invoice may be genuine but still not represent the complete customs value.
Determine whether the importer separately pays:
Under the applicable rules, certain royalties and licence fees related to the imported goods and payable as a condition of sale may need to be added to the customs value.
The importer may have provided the foreign manufacturer free or discounted:
Certain qualifying assists may require an appropriate amount to be added to the transaction value.
Therefore, defending the invoice price does not mean ignoring legally required additions.
Determine whether separate payments involve:
Their customs-value treatment can differ.
The contract and invoice should identify the true nature of the payment.
Check the Incoterm.
Depending on how the transaction is structured, the invoice may or may not already include transportation and insurance costs.
Official guidance confirms that qualifying transport, insurance, loading and handling costs up to the relevant place of entry are included in customs-value calculations.
Avoid double counting.
Where separately identifiable, certain costs incurred after entry may not form part of customs value.
Official guidance specifically addresses matters such as post-entry transportation and certain post-import construction, installation, assembly, maintenance or technical-assistance charges.
Contracts should therefore separate goods and post-import services clearly.
Customs may identify transfers made after importation.
Explain whether they relate to:
Unexplained payments can undermine the valuation defense.
For repeated imports, create a transaction-level reconciliation showing:
Invoice
→ declaration
→ payment
→ accounting entry.
This is particularly useful during post-clearance audits.
Statements such as:
“The supplier gave us a special price.”
are much weaker than:
“The supplier granted a 22% annual-volume discount under the framework agreement, reflected in the attached price schedule and negotiation correspondence.”
Evidence should support every material pricing explanation.
Where transaction value cannot lawfully be used, Customs does not have unlimited discretion to select an arbitrary value.
Official Ministry guidance confirms that the prescribed valuation methods operate sequentially and that the next method should not be used where value can properly be determined under the preceding method.
This can be central to an objection.
If Customs rejects the invoice price, determine:
What method replaced it?
Was the assessment based on:
The importer cannot properly challenge the assessment without knowing its valuation basis.
If Customs relies on identical or similar goods, examine:
Official guidance requires relevant adjustments for proven differences in matters such as commercial level, quantity and transportation.
The comparison should be connected to the relevant import period.
A market price from a substantially different period may not accurately establish the value of the disputed shipment.
Preserve historical price information.
The Ministry’s explanation of the fall-back method expressly states that customs value cannot be based on arbitrary or fictitious values or on a system requiring Customs simply to choose the higher of two alternative values.
This is an important safeguard where the invoice has been rejected.
The importer should identify:
This determines the structure of the objection.
Do not submit hundreds of pages without addressing the actual issue.
If Customs alleges:
related-party influence
submit evidence addressing price independence.
If Customs alleges:
unexplained discount
prove the discount.
If Customs alleges:
additional payment
reconcile the payment.
Once Customs issues an additional assessment or penalty, record the notification date immediately.
Do not allow negotiations with the supplier, broker or Customs office to consume the applicable objection period.
Even if Customs successfully adjusts the customs value, the administrative penalty should be independently examined.
Ask:
Do not assume the penalty automatically follows every valuation adjustment.
If Customs rejects the value of one shipment, it may examine previous imports from the same supplier.
Create a historical matrix showing:
Declaration
Invoice
Supplier
Declared value
Payment
Discount
Customs status.
This helps quantify exposure early.
Ask the supplier to confirm:
Supplier accounting records may also become relevant in complex disputes.
For unusual goods, the importer may need:
The evidence should correspond to the valuation method actually in dispute.
Documents generated contemporaneously with the transaction generally carry greater evidentiary value.
If a supplier later provides an explanatory letter, it should be consistent with the historical:
Contradictions can damage credibility.
For multinational groups, transfer pricing and customs valuation can overlap but are not identical legal systems.
A transfer-pricing report can support the customs file, but it should not automatically be treated as conclusive proof of customs value.
The transaction should still satisfy customs valuation requirements.
For recurring high-value transactions, maintain:
This can substantially reduce disruption during a later Customs inquiry.
The most persuasive file usually shows:
Contract price
=
Invoice price
=
Amount actually paid
=
Accounting records
with documented explanations for any difference.
The more consistent the chain, the easier it is to defend the declared value.
The importer should rapidly collect:
Commercial invoice
→ sales contract
→ purchase order
→ bank transfer/SWIFT records
→ supplier ledger
→ accounting entries
→ pricing correspondence
→ discount documentation
→ comparable sales
→ Incoterm and freight records
→ royalty/licence agreements
→ related-party evidence
→ supplier confirmation
→ Customs valuation decision
→ notification records.
Potentially, but an authentic invoice is not automatically the end of the customs-value analysis. The transaction must satisfy the applicable transaction-value requirements. Turkish rules provide a sequential valuation framework beginning with transaction value.
A low price can trigger scrutiny, but the customs value must be determined through the applicable valuation framework rather than an arbitrary replacement figure.
A consistent chain involving the contract, invoice, bank payment, accounting records and contemporaneous pricing documentation is particularly important.
The relationship alone does not automatically justify rejection of the transaction value. Official Ministry guidance states that the relevant question includes whether the relationship affected the price.
Yes. Quantity and commercial-level differences are relevant when comparing transactions, provided the differences and necessary adjustments can be properly demonstrated.
Certain royalties and licence fees may require inclusion where the statutory conditions are satisfied, including their relationship to the imported goods and payment as a condition of sale.
Comparable transactions can be relevant under the prescribed valuation methods, but differences such as quantity, commercial level and transportation may require adjustment.
The valuation framework does not authorize arbitrary or fictitious customs values. The Ministry’s description of the fall-back method expressly excludes such approaches.
Potentially. Customs may issue additional assessments and penalties depending on the circumstances. The penalty should nevertheless be reviewed separately from the valuation adjustment.
The importer should provide a coherent documentary chain proving how the price was negotiated, invoiced, paid and recorded. If Customs relies on a higher comparable value, the importer should also challenge differences in product specification, quantity, commercial level, timing and transportation rather than defending the invoice with the invoice alone.
Customs valuation disputes may involve:
Rejected invoice prices
Transaction value
Related-party imports
Unusually low prices
Discounts and rebates
Royalty and licence payments
Additional customs assessments
Post-clearance audits
and customs penalties.
Fırat Fesih Kaya Law Office assists foreign manufacturers, multinational companies and importers where Turkish Customs questions or rejects the declared value of imported goods.
Lawyer Fırat Fesih Kaya provides legal assistance in preparing customs valuation evidence, defending transaction values, reviewing related-party pricing, challenging alternative valuation methods, contesting additional assessments and penalties, and managing historical customs exposure.
Phone: +90 312 434 22 22
Mobile: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No:221, Yıldırım Tower, Office No:148, 06520 Balgat, Çankaya, Ankara, Turkey