Customs authorities use somewhat different methods from income tax authorities to value intercompany cross-border transactions in tangible goods. This difference can produce negative outcomes for a business if not considered in the context of total tax liability. This article summarises the relationship between customs valuation and transfer pricing and highlights specific areas for tax planning.
General info
- BDO
- FM Magazine
- KPMG Switzerland – Mind the gap – why operational transfer pricing must include customs
- Deloitte – The Link Between Transfer Pricing and Customs Valuation – 2018 Country Guide
- WCO – Guide to Customs Valuation and Transfer Pricing (2018)
- Tilburgh University – The use of transfer pricing for customs valuation purposes: what should be the criteria for a transfer price in order to meet the customs valuation rules?
- Roedl & Partner – Transfer pricing and customs law: Crucial interdependencies
- ICC – ICC Guidance on Transfer Pricing and Customs Valuation (2015)
Country specifics
- China
- EU: Retroactive intercompany transfer pricing adjustments and customs valuation of imported goods
- ECJ – C-529/16 Hamamatsu – Customs valuation and transfer pricing
- South-Africa: Customs valuation and transfer pricing adjustments receiving focus from authorities
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