Quotation Prasanna, Sayee, Petruzzi, Raffaele. 2018. Restricting the Interplay of Transfer pricing And Customs Valuation. Transfer Pricing International (TPI) 1, 44-46.




The issue of retroactive transfer pricing (TP) adjustments altering customs valuation has been a long-standing question involving many Multinational Enterprises (MNE). While Customs Authorities have traditionally ruled that upward adjustments to transfer prices should be accompanied by revisions to customs value under the transaction value method, MNEs have sought refunds in the event of downward adjustments. Realising the need for guidance, the World Customs Organisation (WCO) continues its efforts to align transfer pricing and customs valuation outcomes. However, in a recent landmark ruling, the Court of Justice of the European Union (CJEU) has affirmed that transfer prices subjected to retroactive adjustments cannot be used for customs valuation purposes under the application of the transaction value method. The ruling leaves open room for diverging interpretations and consequent uncertainties.


Press 'enter' for creating the tag

Publication's profile

Status of publication Published
Affiliation WU
Type of publication Journal article
Journal Transfer Pricing International (TPI)
Language English
Title Restricting the Interplay of Transfer pricing And Customs Valuation
Volume 1
Year 2018
Page from 44
Page to 46
Reviewed? Y
URL https://www.lindeverlag.at/zeitschrift/tpi-18
DOI n.a.


Prasanna, Sayee (Former researcher)
Petruzzi, Raffaele (Details)
Institute for Austrian and International Tax Law IN (Details)
Research areas (Ă–STAT Classification 'Statistik Austria')
5210 Business law (Details)
5307 Business and management economics (Details)
5349 Business taxation (Details)
Google Scholar: Search