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.
This book is a problem-solving guide for lawyers 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, the book offers an account of how tax and customs transfer pricing regimes may be harmonized.
Among the elements of this 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.
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