Customs valuation and transfer pricing : is it possible to harmonize customs and tax rules?
著者
書誌事項
Customs valuation and transfer pricing : is it possible to harmonize customs and tax rules?
（Series on international taxation, v. 28）
Kluwer Law International, 2002
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注記
Includes bibliographical references and index
内容説明・目次
内容説明
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.
目次
Abstract. Acknowledgments. Introduction. Chapter I: General. 1. Rules to be harmonized. 2. Is it necessary or at least advisable to harmonize both tax and customs transfer pricing regimes? 3. Is harmonization feasible? Chapter II: The Arm's Length Principle. 4. Definition -- OECD Guidelines. 5. Recognition of the arm's length principle in the GVC. 6. The OECD Guidelines can be used to determine whether transaction price is arm's length under GVC Article 1.2. 7. Guidance for applying the arm's length principle. Use of such guidance under GVC Article 1.2. Chapter III: Determining Whether the Relationship Influenced the Price. Arm's Length Prices. 8. The OECD arm's length methods and the methods laid down in GVC Articles 2, 3, 5 and 6. 9. Test values. 10. Considerations regarding the OECD arm's length methods. 11. Traditional methods. 12. Other methods. Chapter IV: Tax Bases. Customs Value and Tax Value of Imported Goods. Adjustments. 13. Introduction. 14. IRC Section 1059A. 15. Definition of the term "related parties". 16. Tax base of customs duties. Chapter V: Price Review Clauses and Formula Pricing. 17. Introduction. 18. Price review clauses -- formula pricing. Conclusions. Bibliography. Index.
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