Customs Value and Transfer Pricing: WCO and ICC Solutions to Be Adopted by Customs Authorities

摘要

Intercompany transactions represent nowadays more than 60% of the total market. Businesses dealing with cross-border trade need to comply with the Transfer Pricing (TP) rules for income tax purposes and are obliged to reconcile transfer pricing adjustment with customs value. Such a reconciliation under the traditional customs approach is really burdensome. Just recently, World Customs Organization (WCO) took note of this issue and invited all customs authorities to apply the International Chamber of Commerce (ICC) solutions to ease the customs relation and speed the international trade. The modern approach implies to integrate the TP documentation with a customs dedicated section, establish a transparent discussion with the customs offices and finalize an agreement. It will be the best way to set an effective TP/customs procedure, in any country impacted by the application of the TP policy, to apply the best reconciliation mitigating the administrative costs and neutralizing any risk of sanction in the global marketplace.