The Commerce Department requires the foreign company to prepare a computerized listing of all transactions (i.e. shipments/invoices) of the targeted merchandise during the period under investigation — the last four calendar quarters. The sales price for each of these transactions should be the per-unit invoice price. In preparing this computerized listing, the foreign company should be aware of the following points.

 

First, it is preferable to list separately the original invoice price and all subsequent modifications. This will make the verification process much easier. Accounting systems usually track these adjustments but companies too quickly jump to the final invoice price.

 

Second, the company should be sure the final net sales price provided can tie to the company's financial accounting records. Often a company will use some internal salesperson's management sales system to prepare the required computerized database because, typically, this is the only system that has a product-specific sales database. Such an internal system often does not concern itself with minor price adjustments, such as credits for mistakes in invoicing. Sole reliance on such a system could lead to problems if the total sales value does not tie to the actual amount recorded in the company's financial accounting records as net sales of the targeted merchandise. That is, the Commerce Department requires that the net sales prices reported be the final price charged to the customer.

 

Source: Business Guide to Trade Remedies in the United States: Anti-dumping, countervailing and safeguards legislation practices and procedures