Market leading insight for tax experts
View online issue

Hamamatsu: when transfer pricing and customs valuation converge

Paul Daly (BDO) explains how a recent case has put the relationship between the two under the spotlight, with uncertain consequences for taxpayers.
 

The recently published CJEU case Hamamatsu v Hauptzollamt München (Case C-529/16) is particularly relevant from a customs and transfer pricing point of view as Hamamatsu’s situation is a common one in today’s global economy. The case concerns overlap between retrospective transfer pricing adjustments and the customs valuation of imported goods.

The objective of customs valuation as laid down by the WTO is to ensure a fair uniform and neutral system excluding the use of arbitrary or fictitious customs values. On this basis the general principle is that the customs value must reflect the real economic value of an imported good and take into account all of the elements of that good that have economic value. In the majority of cases the customs value...

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top