(First of two parts)Corporate taxpayers who source imported goods from related foreign suppliers should ensure that they do not only comply with transfer pricing (TP) rules but also with the rules pertaining to the valuation of imported goods for customs purposes. RR 2-2013 also adopts OECD pricing methodologies that include the Comparable Uncontrolled Price Method, Resale Price Method, Cost Plus Method, Profit Split Method and the Transactional Net Margin Method. Unlike in the customs valuation rules, there is no strict priority of methods and no method will invariably be considered more reliable than others. For customs purposes, the transfer price has a direct bearing on the determination of customs value. It is necessary, therefore, that companies address and comply with both TP and customs rules.

Source: Manila Times March 09, 2018 16:18 UTC