Customs Valuation and Transfer Pricing: Is It Possible to Harmonize Customs and Tax Rules? 2nd ed
About this book:
Customs Valuation and Transfer Pricing helps customs administrations to examine the acceptability of a transaction value fixed between related parties in determining the customs value and assists multinational companies in determining acceptable transfer prices for customs purposes and in preparing supporting documentation. Issues of transfer pricing have come to the fore in both international tax and customs regimes. In particular, the problem of how to apply the two systems of valuation to the same transaction is of widespread concern. This well-known book, now in a fully updated second edition, is a problem-solving guide for professionals charged with valuating transactions in their client’s or company’s best interests. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, it offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized.
What’s in this book:
The second edition incorporates many of the relevant intervening international developments in the field; for example, the most recent commentaries, case studies, and draft instruments of the Technical Committee on Customs Valuation and rulings issued by the United States. Among other essential elements, the author discusses the following in depth:
- the OECD Transfer Pricing Guidelines;
- the GATT/WTO Customs Valuation Code (GVC) and other valuation rules in key jurisdictions and regional agreements;
- the OECD and UN model tax conventions;
- the arm’s length principle;
- methods, both traditional and new, of determining whether the parties’ relationship influenced the price; and
- additions to and deductions from the customs value.
This second edition discusses new developments in the field, including a chapter on Commentary 23.1 and Case Study 14.1 of the Technical Committee on Customs Valuation of the World Customs Organization (WCO) – the first international instruments linking transfer pricing and customs valuation. The book concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing year-end adjustments to transaction value would be consistent with Article 1 of the GVC.
How this will help you:
The book will continue to provide practitioners, customs administrations, and academics with a comprehensive knowledge of transfer pricing principles applicable in the tax and customs fields and a highly practical analysis of the intersection of transfer pricing and customs valuation. It will be welcomed by customs administrations charged with examining the acceptability of a transaction value fixed between related parties and multinational companies as a truly actionable tool they can use to optimize decision-making as it relates to transfer pricing and customs valuation in a “real world” setting.
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The Arm’s Length Principle
Determining Whether the Relationship Influenced the Price: Arm’s Length Prices
Tax Bases: Customs Value and Tax Value of Imported Goods – Adjustments
Price Review Clauses and Formula Pricing
Appendix: Additional Case Studies