Transfer Pricing

  • Domestic TP adjustments – impact on customs value?

    Question: Hi! Let´s say you import goods into a country. On a quarterly basis transfer price adjustments are made but the TP adjustments are made domestically, (between entities within a country) to allocate profits. How does this impact the custom value of the imported goods? I claim that the customs value is affected, provided that […]

  • Transfer Pricing Policy Tax or Customs

    QUESTION: Who should own the Transfer Pricing policy, Tax, or Customs Compliance? Should the Transfer Pricing policy be able to meet the requirements for both Tax and Customs? ========== Answers: In organizations for which I have worked, transfer pricing has remained in the global tax department.  There are many more aspects of taxable income, ability […]

  • Export Value Transfer Pricing

    QUESTION: We have a European Warehouse that we move our goods to from the US prior to sale.  The marked up accounting value is transfer price 1. No sale takes place during this movement.  At a later date these goods will be sold to 5 various European Subsidiaries.  These sales would use transfer prices 2-6 […]

  • TRANSFER PRICING AND RECON

    QUESTION: I have a question regarding Customs valuation. By way of background, my company is a wholly-owned U.S. subsidiary of a parent company in Denmark. The parent company sells products to us from a Maquiladora facility in Mexico for import into the U.S. We, the subsidiary, are the importer of record. We, in turn, sell […]

  • Transfer Pricing Related Party

    OT Fact Sheet: Origin Certification Requirements QUESTION: Our company in the USA ships product X to our related subsidiary in Canada, and for this example, we will assume the price on the commercial invoice is $110 (100 Costs + 10% profit). Our subsidiary sells product X to customers in Canada and makes a 40% profit, […]

  • Transfer Pricing Adjustments

    OT Fact Sheet: Origin Certification Requirements QUESTION: Are rebates or discounts that occur before the importation considered “Transfer Pricing Adjustments”? One of our related entities in China has a rebate program with the parent company in the USA, but the rebates/discounts are determined before the importation.  In other words, the price declared on the 7501 […]

  • ANSWERS TO Question on Transfer Pricing Adjustments

    QUESTION: Are rebates or discounts that occur before the importation considered “Transfer Pricing Adjustments”? One of our related entities in China has a rebate program with the parent company in the USA, but the rebates/discounts are determined before the importation.  In other words, the price declared on the 7501 is correct based on the rebate/discount agreed. Since […]