Among other essential elements, the author discusses the following in depth:
- - the OECD Transfer Pricing Guidelines;
- - the GATT/WTO Customs Valuation Code (GVC) and other valuation rules in key jurisdictions and regional agreements;
- - the OECD and UN model tax conventions;
- - the arm's length principle;
- - methods, both traditional and new, of determining whether the parties' relationship in uenced the price; and
- - additions to and deductions from the customs value.
This second edition discusses new developments in the eld, including a chapter on Commentary 23.1 and Case Study 14.1 of the Technical Committee on Customs Valuation of the World Customs Organization (WCO) - the rst international instruments linking transfer pricing and customs valuation. The book concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing year-end adjustments to transaction value would be consistent with Article 1 of the GVC.
The book will continue to provide practitioners, customs administrations, and academics with a highly practical analysis of the intersection of transfer pricing and customs valuation. It will be welcomed by customs administrations charged with examining the acceptability of a transaction value xed between related parties and by multinational companies as a truly actionable tool they can use to optimize decision-making as it relates to transfer pricing and customs valuation in a "real world" setting.
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