WCO Guide to Customs Valuation and Transfer Pricing
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Date
2018
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Publisher
World Customs Organization (WCO)
Abstract
This Guide concerns the relationship between Customs valuation and transfer pricing. It is designed primarily to assist Customs officials responsible for Customs valuation policy or who are conducting audits and controls on multi-national enterprises (MNEs). The 2018 Edition includes updates to reflect developments on transfer pricing at the OECD including the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project (Chapter 3), information on recent texts concluded by the Technical Committee on Customs Valuation (Chapter 4), updates to national initiatives (Annex I) and minor drafting changes. This Guide concerns the relationship between Customs valuation and transfer pricing. It is designed primarily to assist Customs officials responsible for Customs valuation policy or who are conducting audits and controls on multi-national enterprises (MNEs). It is also recommended reading for the private sector and tax administrations who have an interest in this topic. For Customs valuation purposes, import transactions between two distinct and legally separate entities of the same MNE group are treated as ‘related party transactions’. Such transactions may be examined by Customs to determine whether the price declared for the imported goods is ‘influenced’ by the relationship. In other words, is the price at which the goods have been sold at a lower level than it would have been had the parties not been related and the price had been freely negotiated.
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Keywords
Taxation, Transfer Pricing, OECD, Customs Valuation, Tax treaties