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But what is embarrassing is that this downstream situation has not triggered fluctuations in the price of polysilicon, the price of polysilicon. On the contrary, in November, the “No. 58 Document†of the Ministry of Commerce has been implemented, and the downstream demand has been rising. Domestic solar-grade polysilicon prices have fallen slightly.
In view of the sluggish contrast between polysilicon prices and the tightness of PV modules, the latest report released by the China Nonferrous Metals Industry Association Silicon Branch pointed out a possibility: the tax avoidance phenomenon of US polysilicon re-exporting into China through Taiwan is becoming increasingly rampant.
Data show that in October this year, the amount of polysilicon entering Taiwan from Taiwan reached 1,071 tons, accounting for 14.3% of the total imports of the month, and China Taiwan has surpassed the United States for four consecutive months, becoming China's third largest import region. In the same month, China Taiwan imported 1099 tons of polysilicon from the United States.
“The industry knows that Taiwan does not have polysilicon production capacity. But in the customs data, China Taiwan has become the origin of these polysilicon. Then it is basically certain that if someone does not forge the certificate of origin, someone will need to be levied. The high-tariff US silicon material was re-exported to Taiwan, China, and then processed into ingots for export to the mainland, with the purpose of avoiding taxes. In addition, Ma Haitian, deputy secretary-general of the China Nonferrous Metals Industry Association Silicon Branch, also told the Securities Daily. "In October, a total of 1,841 tons of polysilicon imported from the non-tradable trade mode (accounting for 24.5% of the total imports of the month), 1,708 tons of polysilicon entered the customs in the form of 'bonded area warehousing', which required the relevant regulatory authorities to highly valued".
"Bonded Business" Becomes Another Tax Evasion Channel for Overseas Polysilicon
According to customs statistics, China's polysilicon imports in October 2015 were 7,504 tons, down 29.2% from the previous month.
In this regard, the China Nonferrous Metals Industry Association report analysis believes that this is mainly due to the implementation of "Document 58." The "No. 58 Document" issued by the Ministry of Commerce on August 14, 2014 decided to suspend the application for the import of solar-grade polysilicon processing trade from September 1 of the current year. But in fact, in the two weeks after the publication of Document No. 58, the grassroots departments rushed to approve the import of polysilicon processing trade totaling more than 100,000 tons, which not only exceeded the import value of any previous year, but also some contracts. The deadline even crossed the 31st of December, 2014, and the longest sign was in August of 2015.
That is to say, in August 2015, after the completion of the application for the import and export of 100,000 tons of polysilicon processing trade, the "Document 58" was truly effective.
In addition, "In October, China's imports of polysilicon from South Korea significantly decreased to 3,084 tons, a decrease of 37.5% from the previous month" is also an important reason for the decline in the total amount of imported polysilicon. The industry concluded that this is related to the suspension of production and maintenance of individual polysilicon companies in South Korea in the third quarter.
In fact, "Document No. 58" did not completely stop the import of polysilicon processing trade. According to customs data, in October, China's processing trade and other methods imported 1,841 tons of polysilicon, accounting for 24.5%. Among them, 335 tons of polysilicon imported from South Korea according to processing trade, accounting for 10.9% of total imports from South Korea; 219 tons of polysilicon imported from the United States according to processing trade, accounting for 41.1% of total imports from the United States; Imported polysilicon 1246 tons, accounting for 50.7% of the total imports from Germany, is the country with the highest proportion of processing trade in October. According to the analysis of the China Nonferrous Metals Industry Association report, this is mainly due to the delay in the release of German imports in bonded warehouses.
“The processing trade volume in October has rebounded again, mainly due to the special approval of the uncompleted manual orders before August 31.†What is more noteworthy is that an industry insider introduced the “Securities Daily†reporter. "In October, the amount of polysilicon in the warehousing area of ​​the bonded area reached 1,708 tons. In fact, the import volume under this subject has been much higher than in the past this year, which is very abnormal."
According to the reporter, the so-called "bonded business" generally appears in the processing trade contract. For example, feed processing, processing of materials, etc., generally in special customs supervision areas, such as bonded areas, logistics parks, export processing zones, bonded warehouses, etc. "For example, if you do the processing of imported materials and buy bonded raw materials into special supervision areas, you do not need to pay customs duties and value-added taxes first. If you make finished products for export, you can not pay taxes. But if you turn If you sell domestically, you must pay certain tariffs and value-added tax," said the industry insiders.
"According to the regulations, whether the bonded raw materials are exported or domestically sold, when the manual is written off, if there is a difference in the materials used, regardless of the positive or negative, the corresponding tax burden must be paid. But in fact, this cannot completely block the bonded business. The black box operation." An industry insider engaged in the freight forwarding business introduced to the "Securities Daily" reporter, "For example, it is very good at the unit of measurement unit, and it costs a few units of raw materials to produce a unit of finished products. It can be used in units of weights (such as meters, tons, cubic meters, etc.) or natural units (such as blocks, sleeves, pieces, horses, etc.). Relatively speaking, the unit of measurement and measurement is easy to measure, but it is difficult to measure the natural unit. In addition, in order to support local import and export trade considerations, some customs may “close one eye†to the bonded business.â€
The United States borrows from China and Taiwan to evade taxation and South Korea dumps unscrupulously
The China Nonferrous Metals Industry Association Silicon Industry Branch report believes that the most difficult problem facing China's polysilicon market comes from the impact of “re-export trade in Taiwan†and “large dumping in South Koreaâ€.
The data shows that the amount of polysilicon imported from Taiwan in China was 1071 tons in October, accounting for 14.3% of the total imports in the month. In January-October, the total imports from China Taiwan were 8,254 tons, an increase of 14.2% year-on-year. Before June 2015, the proportion of imports from Taiwan and China was basically maintained at around 6%-8%, but since July, the proportion of imports from Taiwan and China has increased year by day, until it hit a record high of 14.3% in October. Overtook the United States as the third largest importer in China.
In October, for example, the total imports from the United States and Taiwan were 1,604 tons, which is almost the same as the number of imports from the United States before the processing trade was unblocked. "It is basically certain that the polysilicon imported from China and Taiwan will enter China's Taiwan from the United States and be re-exported to the mainland after processing into ingots." Ma Haitian said, "Re-exporting anti-circumvention in Taiwan is increasingly significant, which seriously weakens ' The effectiveness of the double-reverse 'and '58 documents' continues to have an impact on domestic polysilicon enterprises. Therefore, it is extremely urgent to block the loopholes in Taiwan.
In addition, China imported 3,084 tons of polysilicon from South Korea in October, accounting for 41.1% of the total imports in the month, a decrease of 37.5% from the previous month (subject to the overhaul of South Korea's HKS in the third quarter). However, from January to October, China imported 42125 tons of polysilicon from South Korea, accounting for 42.7% of the total imports. Imports increased by 49.7% year-on-year.
In the industry's view, the main reason is that the anti-dumping tax rates of South Korea's major exporters OCI and Hankook Silicon are only 2.4% and 2.8%. Anti-dumping duties have no impact on them at all, so South Korea in May 2014 More than the United States and Germany, it has become China's largest source of polysilicon imports, and has maintained its first place for more than a year.
Even if only 2.4% anti-dumping duty is required, the import of polysilicon from South Korea through processing trade in January-October is still 14,323 tons, accounting for 34.8% of the total imports from South Korea, and the total import volume of processing trade in Korea is also in the same place. First, the German processing trade is still 0.5% higher than the second. "Therefore, imports from South Korea, both in terms of total volume and processing trade, have strongly impacted the domestic polysilicon market. Therefore, we should promptly review the dumping of South Korea on the agenda." Ma Haitian told reporters.
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