Aligning transfer pricing and customs valuations

If two branches of a nation's revenue authorities apply different rules for the same transaction, it can lead to double taxation, and has the potential to hurt the investment climate

Historically, customs valuations (CV) and transfer pricing (TP) have been at opposite ends of the spectrum due to the divergent objectives of the two regulations. CV rules are primarily applicable to the import of goods from related parties, whereas TP regulations are applicable to all cross-border transactions between related parties. The fundamental conflict of interest lies in the fact that CV seeks to evaluate if there is under-invoicing of imports, and hence under-payment of customs duty on imports, whereas TP seeks to check if an excess price has been paid for imports from related parties, resulting in the compression of