Guide to Custom Transfer Pricing and Valuation

Abstract

The WCO Guide to Customs Valuation and Transfer Pricing (2018) provides an overview of the relationship between customs valuation and transfer pricing, emphasizing the importance of both methodologies for international trade. This guide targets customs officials, tax administrations, and multinational enterprises (MNEs), offering insights into the valuation of imported goods and the application of the arm’s-length principle. The document explores customs valuation methodologies, adjustments to declared values, and alternate valuation methods under WTO agreements. Additionally, it highlights key transfer pricing concepts, including the comparability of transactions, transfer pricing methods, and regulatory frameworks. Practical guidance is offered on the use of transfer pricing documentation for customs purposes, addressing common challenges such as information access and post-importation price adjustments. The guide underscores the benefits of closer cooperation between customs and tax authorities to improve compliance, trade facilitation, and consistency in determining duty liabilities.