Customs value adjustment (KTS) in Russia: proving your price and appealing a decision
A customs value adjustment is a decision by Russian customs not to accept the value your customer declared for your goods, and to recalculate it on another basis. Here is when it happens, which documents defend your invoice price, and how your customer can challenge the decision.
What a customs value adjustment is, and on what grounds it is made
A customs value adjustment (known in Russia as KTS) is a decision by the customs authority not to accept the value declared by the importer — in this case, your Russian customer — and to recalculate it using a different method. The methods are set out in Chapter 5 of the EAEU Customs Code: method 1 uses the transaction value (the invoice price plus agreed additions); if that cannot be used, methods 2–5 apply in turn (value of identical or similar goods, deductive and computed value), and only as a last resort, method 6, the fallback method.
An adjustment is not something a customs officer can apply at will: a mismatch between the declared price and the Federal Customs Service’s own risk-profile benchmarks is not, by itself, lawful grounds for an adjustment — specific indications that the declared information is unreliable are required. The risk-management system helps customs select which declarations to examine more closely, but it does not replace the need to prove the case.
Sanctions screening comes first
We only handle goods that are not subject to EU, UK, Swiss or US sanctions. Before we quote, we check the HS code of every item and screen all parties to the deal; if a product or a party is restricted, we decline the order, whatever the route or the price.
The situations that most often trigger an adjustment in practice
In practice, an adjustment is most often triggered by: no manufacturer’s price list and no export declaration from the country of dispatch, a mismatch between the amount actually paid and the contract terms, or a transaction between related parties — for example, an import from the parent company of the same group — where customs checks whether the relationship between the parties affected the price.
Royalty and licence payments, and dividends, are a separate issue: if the goods cannot legally be sold in Russia without paying a royalty, that royalty is added to the customs value even though it never appears on the invoice for the goods themselves; the same applies to dividends paid to a related foreign supplier where, in substance, they are part of the income from the sale of the shipment.
Example: a Russian company imports a shipment from its own European division at a price noticeably lower than it charges independent buyers. Customs is entitled to check whether the relationship between the parties understated the price — and the burden of proving otherwise falls on the declarant, your customer, who has to show the price is comparable to what is charged to unrelated buyers.
Which documents actually prove the declared price
There is no single, exhaustive list of documents that proves customs value — only a list of what customs is entitled to request in addition. In practice, the documents that carry real evidential weight are: the manufacturer’s price list, the export declaration from the country of dispatch, payment documents matching the contract terms (a bank-certified copy of the payment order is acceptable), specifications, and transport documents.
Good practice is to assemble this package in advance, not after customs asks for it — especially if the shipment’s price is below the market average for similar goods, in which case it is worth attaching the fuller package of supporting documents to the declaration from the outset.
How to challenge an adjustment decision: two routes
A decision on a customs value adjustment can be challenged in two ways: a complaint to a higher customs authority, or going straight to an arbitration (commercial) court — there is no requirement to exhaust the complaint procedure first. The deadline to go to court is three months from the day the declarant learned that its rights had been infringed, and the burden of proving the decision was lawful rests with customs itself, not with the importer.
A complaint to a higher customs authority is usually examined within about a month (up to two if filed directly with the higher body) — faster than going to court, and with no court fee, so for straightforward cases it is reasonable to start there.
VAT paid on top as a result of an adjustment is not lost: once the goods are booked onto the company’s accounts, it is reclaimed as input VAT in the normal way. Interest charged for the period between release of the goods and the extra payment is treated as lawfully due.
If the cargo is needed urgently, it can be released before the dispute is finally resolved, against security for the disputed payments — a cash deposit or a bank guarantee covering the amount in dispute.
Recent case law: Supreme Court review No. 9/2026
On 17 June 2026 the Presidium of the Russian Supreme Court approved Thematic Review of Case Law No. 9/2026 on customs disputes. Key positions: in transactions between related parties, the declarant must prove the relationship did not affect the price; payments the buyer makes for transport within Russia can be added to the customs value if, in substance, they are part of the price of the goods; and failure to produce one single document is not automatically sufficient grounds to refuse a deduction for transport costs.
For personal or small-batch shipments, the review places the burden of proving an adjustment is needed on the customs authority, and holds that data from websites and catalogues on their own is not conclusive proof that a price was understated.
What this means for the budget of a shipment — and where cargo fits in
The risk of a customs value adjustment only exists for a documented, “white” import with a full declaration lodged in the company’s name. Under an all-in cargo service, the shipment does not go through a declaration in your customer’s company name, so there is no formal KTS risk there either — but along with it go the VAT deduction and the closing paperwork.
Tranzit3 works only with companies and sole traders, from 50 kg per shipment, with a minimum service fee of €200. Our end-to-end customs clearance service (/usluga/customs) checks the declared value against Federal Customs Service risk profiles before the declaration is even lodged. More on customs value generally is in our glossary entry (/slovar/customs-value).
Questions and answers on customs value adjustments
Can my customer avoid paying the extra assessment while the dispute is ongoing?
Generally no — the extra amount is usually required before the goods are released, and the dispute is then about getting it refunded if the decision is overturned.
What defends against an adjustment most effectively?
A complete document package: the invoice, the manufacturer’s price list, the export declaration, the payment order, the specification, and documents on royalties or any relationship between the parties.
Does this only affect high-value shipments?
No — formally, an adjustment is possible at any value, though it is more common where the price is noticeably below the average for similar goods.
Is it worth disputing a small amount?
It depends on the disputed sum relative to the cost of the dispute — worth weighing for the specific figure involved.
Does my customer have to pay before filing a complaint?
No, but while the dispute is unresolved the goods are usually released against security for the payment.
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