Further guidance needed on transfer pricing adjustments and customs valuations in Italy

Customs valuation and transfer pricing rules may result in different values for the same transaction, leading to double monitoring by customs and tax revenue agencies.
Italy’s customs agency has recognised the need to converge tax and customs disciplines for transfer pricing determinations.
The World Customs Organization has specified how customs can take transfer pricing studies into account.
Italy’s working group for the Italian Revenue Agency and customs agency has led to the publication of two circulars, allowing traditional methods for transfer pricing to be used by customs.
Economic operators can submit transfer pricing documentation to customs agencies.
The use of simplified declarations provides flexibility for economic operators when the exact value of goods is unknown at the time of customs clearance.
The treatment of transfer pricing adjustments for customs purposes needs clarification, particularly after the European Court of Justice’s ruling in the Hamamatsu case.