SONRADAN KONTROL: TEORİ VE UYGULAMA

SONRADAN KONTROL: TEORİ VE UYGULAMA

1. Giriş

1994 GATT Anlaşmasının VIII’inci maddesinin 1/c fıkrasında, “Taraflar, ithalat ve ihracatta belge kullanımını azaltma ve basitleştirme ve ithalat ve ihracat formalitelerindeki karmaşıklığı ve mükerrerliği en alt düzeye indirme gerekliliğini kabul ederler” hükmü yer almaktadır.

Ayrıca, 1974 yılında yürürlüğe giren ve Haziran 1999 yılında yeniden gözden geçirilen Kyoto Konvansiyonu’nun (Gümrük Prosedürlerinin Uyumlaştırılması ve Basitleştirilmesi Hakkında Uluslararası Konvansiyon) Gümrük Kontrolü (Customs Control) başlıklı 6’ncı Bölümünde, “Gümrük bölgesine giren veya çıkan tüm mallar, gümrük ve sair vergilere tabi olup olmadığına bakılmaksızın, araçlarıyla birlikte gümrük kontrolüne tabidir.” Hükmü yer almaktadır. Ayrıca, aynı Anlaşma, diğer yasal kontrol yöntemlerine ilave olarak, risk yönetimi ve firma denetiminin kullanılmasını ve modern teknolojilerin uygulanmasını da öngörmektedir.

Öte yandan, 4458 sayılı Gümrük Kanunu’nun 73’üncü maddesinin 1’inci fıkrasında, “Gümrük idareleri, eşyanın tesliminden sonra ve beyannamedeki bilgilerin doğruluğunu saptamak amacıyla, eşyanın ithal veya ihraç işlemlerini veya sonraki ticari işlemlere ilişkin ticari belge ve verileri kontrol edebilirler. Bu kontroller beyan sahibine, söz konusu işlemler ile doğrudan ya da dolaylı olarak ticari yönden ilgili diğer kişilere veya belge ve verileri ticari amaçla elinde bulunduran diğer kişilere ait yerlerde yapılabilir. Mümkün olduğu takdirde eşya muayene de edilebilir.” Hükmü yer almaktadır. Ayrıca, Gümrük Kanunu’nun 71’inci maddesi de, gümrük işlemlerindeki usul ve formalitelerin basitleştirilmesi yönünde hükümler içermektedir.

Görüldüğü üzere, gümrük işlemlerinde sonradan kontrol (post clearance audit) uygulamasının esasları, uluslararası anlaşmalarla belirlenmiş olup başta Batı Avrupa ülkeleri olmak üzere birçok ülkede uygulaması sürdürülmektedir. 4458 Sayılı Gümrük Kanunu’nun 73’üncü maddesi de ülkemizde sonradan kontrolü mümkün kılmaktadır. Çalışmamızda, ilk olarak sonradan kontrol/firma denetimi kavramının teorik olarak açıklaması yapılarak, sonradan kontrolün yararları hakkında bilgi verilecektir. Müteakiben, gümrük idarelerinde kurulacak bir sonradan kontrol sisteminin genel yapısı hakkında fikir verilecek ve nihayet Türk Gümrük Mevzuatının sonradan kontrol hükümleri inceleme altına alınacaktır.

2. Sonradan Kontrol Nedir?

Gümrük kontrol faaliyetlerini genel anlamda iki ana başlık altında toplayabiliriz. Bunlar;

1- İthalat/ihracat işlemleri sırasında kontrol: Belge kontrolü, fiziki muayene, laboratuar kontrolü ve basitleştirilmiş kontrol

2- İthalat/ihracat işlemleri sonrasında kontrol: Ertelenmiş kontrol ve sonradan kontrol

Sonradan kontrol, eşyanın gümrük gözetiminden çıkmasından sonra, beyanların doğruluğunun saptanması amacıyla yapılan gümrük kontrolü veya firma denetimidir. Gümrük kontrol sisteminin son aşamasını oluşturan söz konusu denetim, seçili bir işlemi kapsayacağı gibi, belirli bir döneme ait ithalat veya ihracat işlemlerinin tümünü de içine alabilmektedir. Ayrıca, bu denetim, gümrük idaresinde yapılabileceği gibi ilgili firmada da gerçekleştirilebilmektedir.

Sonradan kontrol, özellikle, belirli risk alanlarında uygunluk denetimi amacıyla yapılmaktadır. Bu alanlar;

a. Kıymet
b. Menşe
c. Tarife

Olarak sınıflandırılabilir.

Sonradan kontrol/firma denetimi; gümrük işlemlerinin ve bu işlemlerle bağlantılı diğer hesap kayıt ve belgelerin kontrolünü kapsamaktadır. Yani yalnızca ithalat ve ihracat işlemi değil gümrükle ilgili (antrepo, menşe, kıymet, onaylanmış kişi vb) tüm işlemlerin kontrolü söz konusudur. Sonradan kontrol, sadece firmaların yaptığı işlemlerin kontrolü değil yapacağı işlemlere ilişkin hem kontrol hem de bilgi alış-verişinin yapılmasını da kapsar. Yine gümrük işlemleriyle bağlantılı muhasebe kayıtlarının, kambiyo hareketlerinin, çalışanların mevzuat bilgilerinin kontrolünü de içerir. Bu anlamda etkili ve verimli sonuç alınması için sonradan kontrol/dış denetim/firma denetimi yapacak kişilerin gümrük mevzuatının yanı sıra muhasebe bilgisi konusunda da eğitim almış olması gerekmektedir.
Çalışmamızın bundan sonraki bölümünde, sonradan kontrol/firma denetimi deyimi yerine, firma denetimini de kapsayacak şekilde sadece sonradan kontrol deyimi kullanılacaktır.

3. Sonradan Kontrolün Başlıca Yararları

a) Gümrük işlemlerinin basitleştirilmesiyle birlikte, ithalatçı ve ihracatçıların gümrüklerde harcadıkları süre en aza indirilerek, bu kişilerin mallarının dağıtımını hızlı bir şekilde yapmalarına imkân sağlanmaktadır.

Geleneksel gümrük işlemlerinin uygulandığı gümrük idarelerinde, eşyalar sınır kapılarında veya limanlarda gümrük kontrolüne tabi tutulmaktadırlar. Bu işlem ise, eşyaların günlerce bazen de haftalarca gümrük gözetimi altında kalmasına yol açabilmekte, dolayısıyla sonradan kontrol, bu olumsuzluğu da ortadan kaldırmaktadır.

b) Sonradan kontrol ve risk yönetimi tekniklerini kullanan gümrük idareleri, sadece yapılan işleme dayalı kontrolden, daha gelişmiş firma odaklı denetime geçme fırsatını yakalayabilmektedirler.

c) Sonradan kontrol yöntemi, mevcut bilgilerin analizine ve ilgili ithalat işlemi ve firma hakkındaki istihbarat bilgilerine dayandığı için daha etkili bir kontrol tekniğidir.

d) Menşe ülkelerinin veya farklı göndericilerin birbirleriyle karşılaştırılmaları sonucunda, düşük kıymet gibi yanlış beyanlar kolaylıkla tespit edilerek, eksik alınan gümrük vergisi ve ilgili diğer vergiler tahsil edilebilecek ve hazine gelirleri bu şekilde artırılabilecektir.

e) Eşyaların gümrüklerde bekleme sürelerinin azaltılmasıyla birlikte gümrük memurlarının gerek planlama ve gerekse acil denetimlere yeterli zaman ayırmaları sağlanacak ve böylece personel daha etkin bir şekilde görev yapabilecektir.

f) Malların gümrüklerden ilişik kesme sürelerinin azalması, iş sahiplerinin rekabet gücünü de artıracaktır.
g) Malların gümrüklerde bekleme sürelerinin azaltılması, hem depolama ve hem de sigorta masraflarında tasarrufa yol açabilecektir.

4. Sonradan Kontrol Sisteminin Uygulama Koşulları

Sonradan kontrol, oldukça karmaşık ve sonuçları itibariyle çok önemli bir süreçtir. Bu nedenle, etkili bir sisteminin kurulması, önceden yapılacak kapsamlı çalışmaların ve yatırımların varlığına bağlıdır. Bu ön koşulları kısaca açıklayalım:

a) Etkin bir sonradan kontrol sisteminin kurulabilmesi, öncelikle idarenin en üst yöneticilerinin kararlılığını ve desteğini gerektirmektedir.

b) Gümrük İdaresi, etkili bir denetim stratejisi geliştirerek, personeline, uygulamaya yönelik rehberlik hizmeti vermelidir.

c) Sonradan kontrol ile görevlendirilecek personelin, sistemin avantajlarından en iyi şekilde istifade edebilmelerini teminen, analitik çalışma teknikleri, etkili kontrol metotları konularında kapsamlı eğitime tabi tutulmalıdır.

d) Sonradan kontrol çoğunlukla ilgili firmalar nezdinde yapıldığı için, firma denetiminin sağlıklı olması açısından, gümrük idareleri ile firmalar arasında olumlu bir işbirliğinin geliştirilmesi gerekmektedir.

e) Her ne kadar sonradan kontrol manuel olarak veya yarı-otomatik ortamlarda yapılabilmekte ise de otomasyon etkin bir kontrol sisteminin vazgeçilmez bir unsuru olarak değerlendirilmelidir.

f) Sonradan kontrolün, belge incelemesinin yanı sıra malların fiziki kontrollerini de kapsayacağı ve bu denetimin firmalarda yapılacağı göz önüne alınarak, gerek gümrük kanunlarında ve gerekse ilgili diğer mevzuatta gerekli değişiklikler yapılmak suretiyle, yeni kontrol sistemlerinin usul ve esasları düzenlenmeli ve idarenin yetkileri açıkça belirtilmelidir.

g) Kurulacak bir sonradan kontrol sistemi aynı zamanda, etkili bir risk yönetimi sistemini de gerekli kılmaktadır.

5. Yeni Kurulacak Bir Sonradan Kontrol Sisteminin Çerçevesi

Etkili bir sonradan kontrol sisteminde, öncelikle risk yönetimiyle harekete geçilir. Daha sonra denetlenecek firma ile iletişim ve işbirliğine gidilir. Bunu profesyonel bir denetim ile firmanın dahili kontrolü takip eder. Denetim raporunun bir örneği firmaya gönderilir ve nihayet sonuçlar değerlendirilerek firma denetimi tamamlanır. Bu noktada, yeni kurulacak bir sonradan kontrol sisteminin genel yapısının aşağıdaki gibi olması önerilmektedir:

SONRADAN KONTROL PROGRAMININ OLUŞTURULMASI

• İthalatçı/İhracatçı Kontrolü
• Gümrük Müşaviri Kontrolü
• Taşıma Manifestosu Kontrolü
• Serbest Bölge Kontrolü

RİSK YÖNETİMİ

STRATEJİ PLANLAMASI

POTANSİYEL DENETİM HEDEFLERİNİN BELİRLENMESİ

• Kıymet
• Menşe
• Tarife
• İstisnalar/Muafiyetler

FİRMALARIN/KİŞİLERİN SEÇİMİ

DENETİM HAZIRLIKLARI

• Denetçilerin/denetim ekiplerinin görevlendirilmesi
• Denetim kapsamının belirlenmesi
• Firma ile iletişim kurulması
• Firmadan bilgi istenilmesi
• Sualname gönderilmesi
• Firma beyannamelerinden veri Sağlanması

DİĞER GÜMRÜK İDARELERİ İLE İRTİBAT

SONRADAN KONTROLÜN YÜRÜTÜLMESİ

• Ön toplantılar yapılması
• Kayıtların incelenmesi
• Firma kayıtlarının teyit edilmesi
• Uygunluğun saptanması

SONRADAN KONTROLÜN BİTİRİLMESİ

• Rapor hazırlanması
• Sonuçların firmaya bildirilmesi
• Sonuçların ilgili gümrük idarelerine rapor edilmesi

SONUÇLARIN DEĞERLENDİRİLMESİ VE SÜRECİN TAMAMLANMASI

6. Türk Gümrük Mevzuatında Sonradan Kontrol ve Uygulama

2913/92 sayılı AB Gümrük Kodu’nun 78’inci maddesi ile benzer hükümler içeren 4458 Sayılı Gümrük Kanunu’nun 73’üncü maddesi, gümrük idarelerinin, eşyanın tesliminden sonra ve beyannamedeki bilgilerin doğruluğunu saptamak amacıyla eşyanın ithal veya ihraç işlemlerini veya sonraki ticari işlemlere ilişkin ticari belge ve verileri kontrol edebileceklerini belirtmektedir. Bu kontrollerin beyan sahibine veya ilgili diğer kişilere ait yerlerde de gerçekleştirlebileceği ve mümkün olduğu takdirde eşyanın fiziki muayenesinin de yapılabileceği aynı madde ile hüküm altına alınmıştır.

Ancak, evrensel anlamda “sonradan kontrol” kavramına uygun olarak, bir firmanın belirli bir döneme ait tüm dış ticaret işlemlerinin düzenli olarak denetlenmesi yöntemi henüz ülkemizde tam olarak uygulamadaki yerini alamamıştır. Gümrük Kanunu’nun 73’üncü maddesi tüm beyanların sonradan kontrolünü mümkün kılarken, bu madde ile ilgili düzenlemeler içeren, Gümrük Yönetmeliği’nin 207’inci maddesi sadece “mavi hatta” sevkedilen, “basitleştirilmiş usule” tabi beyannamelerin kontrolünü düzenlemektedir. Bu noktada, Gümrük Yönetmeliği’nin, sonradan kontrole ilişkin düzenlemeler açısından yetersiz olduğunu söylememiz mümkündür.

Son yıllarda, Gümrükler Genel Müdürlüğü tarafından yapılan risk analizleri sonuçlarına dayanılarak, sektörel bazda, Gümrük Kontrolörleri tarafından gerçekleştirilen firma denetimlerini, ülkemizdeki sonradan kontrol faaliyetlerinin başlangıç noktası olarak değerlendirmemiz mümkündür. Gümrük Yönetmeliği’nin 207’inci maddesi kapsamında, Muayene Memurlarının işyeri ziyaretleri yapmak suretiyle gerçekleştirdikleri denetimler ise, sonradan kontrol/firma denetiminden ziyade, Gümrük Kanunu’nun 71’inci maddesinde düzenlenen basitleştirilmiş usul kapsamında, eşyanın firmada muayene edilmesi işlemleri olarak algılanmalıdır.

Bu noktada, Gümrük Kanunu’nun 73’üncü maddesinde düzenlenen sonradan kontrol işlemleri ile ilgili esas ve usullerden ziyade Kanun’un 71’inci maddesinde düzenlenen Basitleştirilmiş Usul işlemlerine açıklık getiren Gümrük Yönetmeliği’nin 207’inci maddesine göre yürütülen faaliyetleri açıklamakta yarar bulunmaktadır. Buna göre;

Gümrük mevzuatına göre ön incelemeleri yapıldıktan sonra “Onaylanmış Kişi Statü Belgesi” verilen firmalar vergi numarasına göre bilgisayar sistemine tanıtılmakta ve “mavi hatta” giren firmaya ait eşyaların muayenesi yapılmamaktadır. Bu hatta düşen eşyanın kontrolü daha sonraki aşamada belge üzerinden yapılmakta, gerek görülürse firma kayıtları da incelenebilmektedir. Gelişmiş ülkelerde en çok işlem görülen hat yeşil/beyaz hat olup (%90 üzerinde), risk analizleri sonucunda sevkiyatların büyük çoğunluğu gümrük kontrolüne tabi tutulmamaktadır. Ülkemizde ise yeşil hat uygulaması yok denecek kadar az olup, sonradan kontrole tabi mavi hat uygulaması %25 civarındadır.

Diğer taraftan, 01.01.2006-30.06.2006 tarihleri arasında tescil edilen ithalat gümrük beyannamelerinin (otomasyona geçmiş gümrük idarelerince), BİLGE sistemi tarafından yaklaşık % 27’si “kırmızı hat”, % 48’i “sarı hat” ve %25’i ise “mavi hat” a sevkedilmiştir.

Ayrıca, Risk kriterlerine göre basitleştirilmiş kontrol yöntemine tabi tutulan gümrük beyannamelerinin gümrük idaresi nüshaları, basitleştirilmiş kontrol servisinde toplanmakta, bu serviste görevli muayene memurları beyanname ve sistem üzerindeki bilgiler ile beyanı tevsik eden belgelerdeki bilgileri karşılaştırmaktadırlar. İlgili muayene memuru tarafından yapılan belge kontrolü sonucunda, uygun sonuç alınması durumunda BİLGE ekranına ve beyannamenin döküm nüshası üzerine “Kontrolü yapılmış ve uygun sonuç alınmıştır” meşruhatı düşülerek beyanname imzalanmaktadır.
Muayene memuru yaptığı inceleme sırasında beyanname ve ekli belgeler arasında ciddi bir farklılık görür ve fiziki muayenenin yapılmasına karar verir ise; durumu bir müzekkere ile idari amirine bildirmektedir. İdari amirinin fiziki muayeneyi uygun görmesi halinde, ilgili muayene memuru ile birlikte başka bir muayene memuru veya gümrük memuru görevlendirilmekte, bu memurlar eşyanın bulunduğu depo, fabrika veya işletmeye giderek eşyanın fiziki muayenesini yapmaktadırlar. Eşyanın bulunduğu duruma göre stok deposunda, üretim bandında, mamul stok ambarında veya firmanın muhasebe kayıtlarında gerekli inceleme yapılarak muayene sonuçları bir tutanağa bağlanmaktadır. Ayrıca, eşyanın gümrük işlemleri veya sonraki ticari işlemlere ilişkin ticari belge ve veriler de kontrol edilebilmektedir.

Öte yandan, 31 Seri Nolu Gümrük Genel Tebliği (Gümrük İşlemleri), “Onaylanmış Kişi Statü Belgesi” için yapılacak müracaatta aranacak belgeler, belgenin kullanımı, süresi, yenilenmesi, geçici olarak geri alınması ile iptaline ilişkin usul ve esaslar ile basitleştirilmiş usuller, basitleştirilmiş kontrol yöntemi, basitleştirilmiş işlem kapsamında A.TR düzenleme, onaylama ve vize işlemleri ile kısmi teminat işlemlerine ilişkin usul ve esasları belirlemektedir. Buna göre;

Gümrük Yönetmeliğinin 207’nci maddesi kapsamında basitleştirilmiş kontrol yöntemi uygulamasından; A ve B Sınıfı Onaylanmış Kişi Statü Belgesi sahibi kişiler yararlandırılmaktadır.

Söz konusu Tebliğin basitleştirilmiş kontrol yöntemine ilişkin hükümleri bilgisayar sistemi (BİLGE) bulunan gümrük idarelerinde geçerlidir.

Basitleştirilmiş kontrol yöntemi, risk kriterlerine göre, belge kontrolü ve fiziki muayene yapılmadan teslim edilen eşyanın teslimden sonra gümrük beyannamesi ile ticari belge ve verileri incelenerek gerektiğinde eşyanın fiziki muayenesinin imalathane, fabrika, özel depo, işyeri ve benzeri yerlerde yapılmasını ifade etmektedir.

Tebliğ’de belirtilen usul ve esaslar dahilinde yapılan, eşyanın fiziki muayenesini de içeren basitleştirilmiş kontrol sonucunda; 4458 sayılı Gümrük Kanunu, 4926 Sayılı Kaçakçılıkla Mücadele Kanunu, 5237 Sayılı Türk Ceza Kanunu ile Dış Ticaret Mevzuatı gereği ceza gerektiren bir fiilin tespiti halinde derhal takibata başlanmakta ve durum derhal Başmüdürlükler kanalıyla Gümrük Müsteşarlığı’na (Gümrükler Genel Müdürlüğü) iletilmektedir.

Basitleştirilmiş Kontrol uygulamasından yararlanmak üzere, Onaylanmış Kişi Statüsü ve buna ilişkin belge verilen kişiler; yürürlükteki dış ticaret ve gümrük mevzuatına uymak, kontrolleri olanaklı hale getirecek her türlü kolaylığı göstermek, ilgili bütün belge ve verileri kontrolü yapan gümrük personeline ibraz etmek, zorundadırlar. Sözkonusu, yükümlülükleri yerine getirmeyenlerin Onaylanmış Kişi Statüsü iptal edilmektedir.

Öte yandan, Gümrükler Genel Müdürlüğü’nün tüm Gümrükler Başmüdürlükleri’ne yönelik 26.03.2003/07246 tarihli/sayılı tasarruflu yazısında, Gümrük Yönetmeliğinin 207’inci maddesi kapsamında sonradan kontrol işlemine tabi tutulan (mavi hatta işlem gören) beyannamelere ilişkin yapılacak inceleme ve kontrollerin yanında, işyerlerine yapılacak ziyaretler suretiyle gerçekleştirilecek inceleme ve kontroller hakkında düzenlemeler öngörülmektedir. Buna göre;

Mevzuat dahilinde, sonradan kontrol işlemine tabi tutulan beyannamelerden gümrük muayene memurunun yaptığı inceleme sırasında beyanname, ek belgeler ve ekran bilgileri arasında ciddi bir farklılık bulunmayanlar da dahil olmak üzere, Gümrük Müdürlükleri itibariyle (Ocak-Mart), (Nisan-Haziran), (Temmuz-Eylül) ve (Ekim-Aralık) şeklinde üçer aylık dönemleri kapsayacak şekilde; tescil edilmiş sonradan kontrole tabi beyannamesi sayısı;
5000 ve yukarısında olanlar için % 2 (en az 100, azami 120)
2000 ile 4999 arasında olanlar için % 3 (en az 60, azami 100)
1000 ile 1999 bin arasında olanlar için % 4 (en az 40, azami 60)
999 ve aşağısında olanlar için % 5 (en az 5, azami 40)
Oranlarında örnekleme yöntemiyle farklı firmalara ait olması da dikkate alınarak, özellikle gümrük vergi oranı, geldiği ülke ve menşe ülke gibi riskli sayılabilecek durumlar göz önünde bulundurularak belirlenen gümrük beyannameleri kapsamı eşyanın, işyeri ziyareti yapılmak suretiyle fiziki muayene, inceleme ve kontrole tabi tutulmasının sağlanması için yeterli sayıda gümrük muayene memuru görevlendirilmektedir.

Bu memurlar eşyanın bulunduğu depo, fabrika veya işletmeye giderek gümrük muayenesini yapmaktadırlar. Bu süre içerisinde eşya, malzeme stok deposundan çıkarılmış olması durumunda üretim bandında, üretim bandından çıkmış ise mamul stok ambarında, bu ambardan çıkarılarak satılmış ise firmanın muhasebe kayıtlarında gerekli inceleme yapılarak muayene sonuçlarını bir tutanağa bağlamaktadırlar.

7. Sonuç

Tanımından da anlaşılacağı gibi sonradan kontrol, belirli bir olay hakkında yapılan kaçakçılık soruşturması veya bir inceleme nedeniyle, sadece bu olaya ilişkin bilgi ve belgelere dayanılarak yapılabileceği gibi, bir firmanın belirli bir döneme ait ithalat ve ihracat işlemlerini kapsayacak şekilde tüm dış ticaret işlemlerinin firma bazında denetlenmesi şeklinde de yapılabilmektedir. Ülkemizde ise daha ziyade, Gümrük Müsteşarlığı Merkez Denetim Elemanları tarafından, eskiden beri süregelen ve olay bazında yapılan firma denetimlerinin, sonradan kontrol kavramının kapsamına girdiği söylenebilir. Mevzuatta herhangi bir engel bulunmamasına rağmen, bir firmanın belirli bir döneme ait tüm dış ticaret işlemlerinin düzenli olarak denetlenmesi yöntemi henüz ülkemizde uygulamada yerini alamamıştır. Gümrük Yönetmeliği’nin 207’inci maddesi kapsamında, Muayene Memurlarının işyeri ziyaretleri yapmak suretiyle gerçekleştirdikleri denetimlerin, sonradan kontrol/firma denetiminden ziyade, Gümrük Kanunu’nun 71’inci maddesinde düzenlenen basitleştirilmiş usul kapsamında, eşyanın firmada muayene edilmesi olarak algılanması gerekir.

Öte yandan, Gümrük Kanunu’nun 73’üncü maddesinde belirtilen, eşyanın tesliminden sonra beyanın kontrolü ile ilgili işlemler ile bu işlemlerin verimliliğini artıracak risk yönetimi faaliyetlerini sistemli ve düzenli bir şekilde yürütmek ve ilgili kurum ve kuruluşlar arasında koordinasyonu sağlamak, denetlenecek firmalarla ilişkileri düzenlemek üzere, Gümrük Müsteşarlığı bünyesinde, ayrı ve müstakil bir birim kurulması ihtiyacı ortadadır.

Son yıllarda, Maliye Bakanlığı ve TÜRMOB ile işbirliğine gitmek suretiyle gerek merkez ve gerekse taşrada görevli personeline sonradan kontrol ve muhasebe-vergi incelemesi eğitimi veren Gümrük Müsteşarlığı’nın bu faaliyetlerinin artarak devam etmesi son derece yararlı olacaktır. Zira, etkili bir sonradan kontrol sistemi, firmaların belge ve kayıt sistemlerini belirli bir standarda kavuşturmaları, tüm gümrük idarelerinin otomasyona dahil edilerek iyi organize edilmiş bir risk yönetimi kapsamına alınmalarının yanında, firma denetimi konusunda yetişmiş denetçilerin varlığını da gerekli kılmaktadır.

Kaynakça :

1- Ali NURAL, “Sonradan Kontrol – Firma Denetimi”, Gümrük Dünyası Dergisi, Sayı:47.
2-“Customs Procedures – Post Clearance Audit”, UNCTAD Technical Note No.05 http://www.gfptt.org/Entities/ReferenceReadingProfile.,
3- Council Regulation (EEC) No 2913/92 of 12 October 1992 establishing the Community Customs Code
4- Dietmar JOST, “Revised Kyoto Convention, Audit-based controls”, World Customs Organization.
5- “Guidelines for Customs Audits”, http://www.basis.ie/servlet/blobservlet/custaudt%5B1%5D.pdf?
6- İlteriş Kutluk BAHAR, “Sonradan Kontrol mü, Sıcağı Sıcağına Kontrol mü?”, Divan Dergisi, Temmuz-Eylül 2006, Sayı:3.
7- “Revised Kyoto Convention”, http://www.wcoomd.org/ie/En/en.html
8- “Risk management – Post-clearance control”,http://www.wcoomd.org/ie/WTO/Risk%20Management
9- Süleyman KARADURMUŞ, “İthalat İşlemleri, Gümrük Mevzuatı ve Dış Ticaret Mevzuatı”, Malatya, 2005.
10- “The General Agreement on Tariffs and Trade (GATT 1947)” http://www.wto.org/english/docs

http://www.gumrukkontrolor.org.tr/Yayinlar/Dergiler/53/8.html

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