Transfer Pricing and Customs Valuation

Transfer Pricing and Customs Valuation PDF Author: Anuschka Bakker
Publisher: IBFD
ISBN: 9087220596
Category : Customs appraisal
Languages : en
Pages : 695

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Book Description
This book discusses the intricate role of transfer pricing and customs value in international business environment. It examines the relationship between valuation for transfer pricing purposes and valuation for customs, and the significance of the relationship for multinational enterprises, tax authorities and customs administrations. The book begins by reviewing relevant international standards such as the OECD Guidelines and the GATT/WTO Customs Valuation Agreement. This is followed by a discussion of related issues such as VAT and administrative matters. Country chapters provide an overview of the applicable legislation and valuation methods, and case studies allow direct comparison between the practices of the different countries. The book concludes by summarizing the existing relationship between transfer pricing valuations and customs valuations, and by suggesting possible solutions towards a more integrated approach.

Transfer Pricing and Customs Valuation

Transfer Pricing and Customs Valuation PDF Author: Anuschka Bakker
Publisher: IBFD
ISBN: 9087220596
Category : Customs appraisal
Languages : en
Pages : 695

Get Book

Book Description
This book discusses the intricate role of transfer pricing and customs value in international business environment. It examines the relationship between valuation for transfer pricing purposes and valuation for customs, and the significance of the relationship for multinational enterprises, tax authorities and customs administrations. The book begins by reviewing relevant international standards such as the OECD Guidelines and the GATT/WTO Customs Valuation Agreement. This is followed by a discussion of related issues such as VAT and administrative matters. Country chapters provide an overview of the applicable legislation and valuation methods, and case studies allow direct comparison between the practices of the different countries. The book concludes by summarizing the existing relationship between transfer pricing valuations and customs valuations, and by suggesting possible solutions towards a more integrated approach.

Customs Valuation and Transfer Pricing

Customs Valuation and Transfer Pricing PDF Author: Juan Martin Jovanovich
Publisher: Kluwer Law International B.V.
ISBN: 9041161422
Category : Law
Languages : en
Pages : 216

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Book Description
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. 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 in uenced the price; and – additions to and deductions from the customs value. This second edition discusses new developments in the eld, 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 rst 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. The book will continue to provide practitioners, customs administrations, and academics with 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 xed between related parties and by 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.

Customs Valuation and Transfer Pricing:Is It Possible to Harmonize Customs and Tax Rules?

Customs Valuation and Transfer Pricing:Is It Possible to Harmonize Customs and Tax Rules? PDF Author: Juan Jovanovich
Publisher: Springer
ISBN:
Category : Business & Economics
Languages : en
Pages : 168

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Book Description
Although valuation is fundamental to both tax and customs liability in international transactions, values calculated by the two regimes can differ, often markedly, in situations where no clear rules of transfer pricing apply. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, Customs Valuation and Transfer Pricing offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized.Among the essential elements of this important thesis, the author discusses the following in depth: the OECD Transfer Pricing Guidelines; the GATT/WTO Valuation Code (GVC); 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. The study concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing compensatory adjustments to transaction value would be consistent with Article 1 of the GVC.

Customs Valuation and Transfer Pricing [microform] : is it Possible to Harmonize Customs and Tax Rules?

Customs Valuation and Transfer Pricing [microform] : is it Possible to Harmonize Customs and Tax Rules? PDF Author: Juan Martin Jovanovich
Publisher: National Library of Canada = Bibliothèque nationale du Canada
ISBN:
Category : Tariff
Languages : en
Pages : 294

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Book Description


A Handbook on the WTO Customs Valuation Agreement

A Handbook on the WTO Customs Valuation Agreement PDF Author: Sheri Rosenow
Publisher: Cambridge University Press
ISBN: 1139495364
Category : Law
Languages : en
Pages : 287

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Book Description
This guide to the WTO Customs Valuation Agreement is based on the authors' experiences of teaching its finer points to customs officials and policy-makers around the world. Covering the methods of valuation and the provisions on enforcement, implementation and dispute settlement, the authors give practical examples, explain interpretative decisions of national and international customs bodies, and analyse the history of its negotiation. Written as a learning tool, it helps both new and experienced policy-makers, customs officials, importers and exporters to gain a deeper understanding of the Agreement's function and aims.

The Customs Valuation Agreement

The Customs Valuation Agreement PDF Author: Mark K. Neville
Publisher: Kluwer Law International B.V.
ISBN: 9403531460
Category : Law
Languages : en
Pages : 360

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Book Description
Global Trade Law Series, Volume 58 Customs valuation is a key element in the corpus of international trade law. Despite the facts that the /WTO Valuation Agreement 1994 remains unchanged in all material respects and that it has been adopted by virtually every trading nation on the planet, there are fissures in the system preventing consensus on many contentious questions. This extremely knowledgeable analysis by a world-renowned specialist lawyer in the field—by concentrating on diverging views on the nature of the central feature of the Agreement, the definition of the price actually paid or payable (PAPP)—provides the most extensive study available of the origins and architecture of the Valuation Agreement and its intersection with transfer pricing norms. Among much else, the author fully explains differing views on such questions as the following: criteria governing royalties and license fees; acceptability of the First Sale for Export doctrine; role of transport charges in valuing dutiable assists; status of interest payments on deferred payments; valuation of carrier media bearing software for data processing equipment; inclusion or exclusion of transport charges in the PAPP; status of the WTO’s moratorium on electronic transmissions; status of payments of money for tools and other materials used in producing the imported goods; and status of international instruments of traffic. The author expertly assesses interpretations of the Valuation Agreement as presented in the instruments of the World Customs Organization and in the administrative and judicial fora of the United States, Canada, and the European Union. This matchless book takes a giant step toward “real-world” consensus on the daunting questions of custom valuation. Customs and international tax professionals, as well as academic scholars, will come away from its in-depth coverage with an enhanced ability to discern the logic inherent in the Valuation Agreement, a greater awareness of current trends and their origins in authoritative customs valuation bodies, and improved confidence when approaching customs valuation questions.

Transfer Pricing Rules and Compliance Handbook

Transfer Pricing Rules and Compliance Handbook PDF Author: Marc M. Levey
Publisher: CCH
ISBN: 9780808015536
Category : Business & Economics
Languages : en
Pages : 232

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Book Description
This book gives an overview of the basic principles of transfer pricing and U.S. transfer pricing rules, and the impact of transfer pricing on other issues such as customs valuation, Section 404 of the Sarbanes-Oxley Act of 2002, and FASB Interpretation no. 48.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264921915
Category :
Languages : en
Pages : 659

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Book Description
In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.

Taxmann’s Guide to Customs Valuation – Complete & comprehensive commentary in a brief/concise/handy format, providing updated & simplified analysis to determine valuation under Customs Laws

Taxmann’s Guide to Customs Valuation – Complete & comprehensive commentary in a brief/concise/handy format, providing updated & simplified analysis to determine valuation under Customs Laws PDF Author: H.K Maingi
Publisher: Taxmann Publications Private Limited
ISBN: 939083192X
Category : Law
Languages : en
Pages : 18

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Book Description
Guide to Customs Valuation is a complete and comprehensive commentary on laws relating to valuation under Customs laws. It is a brief, concise and handy reference book, which provides the updated and simplified analysis of provisions to determine valuation under the Customs laws. This book will be helpful for Customs Consultants, Advocates, Corporate Managers & Departmental Officers. This book is divided into two parts: · Valuation of Imported Goods · Valuation of Export Goods The Present Publication is the Latest Edition, authored by H.K. Maingi, amended up to July 2021, with the following noteworthy features: · [Conceptual Understanding of Valuation] Conceptual understanding of provisions of Valuation under Section 14 of Customs Act and Customs Valuation (Determination of Value of Export Goods) Rules, 2007 · [Valuation] Valuation of Imported Goods & Exported Goods, Valuation in case of High Sea Sales & related persons, Valuation of capital goods on debonding, etc. · [Various Additions in Transaction Value] Various additions in Transaction Value such as Brokerage, Service Charge, Transportation, etc. · [Other Concepts] Concepts of related persons, under-invoicing and over-invoicing, Special Valuation Branch, etc. This edition covers everything you need to understand about the provisions of Valuation under Customs in a subtle and simplified language. The detailed coverage of the book is as follows: · Introduction · Valuation of Imported Goods o Transaction Value o Transaction Value to be Accepted in the Absence of Condition and Restriction under Rule 3(2) o Contract Prices and Transaction Value o High Sea Sales and Transaction Value o Related Persons o Transaction Value of Identical or Similar Goods and Contemporaneous Imports o Deductive Value o Computed Value o Residual Method o Reliance on Foreign Journals indicating International Prices for Determining Assessable Value o Addition to Transaction Value Royalty, Licence and Technical Know-How Fees o Other Addition to Transaction Value o Declaration by the Importer o Rejection of Declared Value o Investigation by Special Valuation Branch · Valuation of Export Goods o Export Valuation o Under-Invoicing and Over-Invoicing of Exports o Customs Valuation (Determination of Value of Export Goods) Rules, 2007 o Inclusion/Exclusion Duty Element from Cum Duty Price o Valuation of Goods Sold in DTA from EOU and Debonding of Capital Goods from EOU

Transfer Pricing in International Business

Transfer Pricing in International Business PDF Author: Geoff Turner
Publisher: Business Expert Press
ISBN: 1606493493
Category : Business & Economics
Languages : en
Pages : 114

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Book Description
For centuries, trade has endured stumbling blocks, mistakes, and moments of inspiration. It has contributed to the modern, globalized world in which we live, and the increasing economic, social, and political importance of trade has spawned a phenomenon called the multinational organization. However, these organizations have a national home to where profits will ultimately have to come, and in their effort to maximize the amount repatriated, they often engage in internal-pricing practices, known more commonly as transfer pricing This book reminds us all of the important issues of transfer pricing, and how easy it is to create friction between all of the interested parties. This book also goes on to provide an insight into how such conflicts can be assuaged or avoided altogether, and explains how transfer pricing may become a managerial tool by establishing a common language that may be used as one driver for creating added value throughout the organization. Transfer pricing is not simply about maximizing income. It is a much more important strategic management issue that, treated unwisely or with ignorance, is likely to lead to an incongruity in the added value of an organization’s products and services as well as its crucial return on capital employed.