Global Trade & Tax Advisory LinkedIn Contact Us
The Valuation Risk Iceberg
Invoice Price (10%)
Visible Transaction Value
Royalties & Licence Fees
Assists (Tooling/Design)
TP Adjustments (Year-End)
R&D Costs & Engineering
Audit Defense

Are your "Add-ons" correctly apportioned? Avoid penalties under UCC Art. 71.

1. The WTO Valuation Hierarchy

Application of the transaction value (Method 1) is not automatic. In intercompany flows, we must prove the relationship did not influence the price.

Method 1: Transaction

Acceptable only if there is a "Sale for Export" and the price is not distorted by the relationship (Test Values).

Methods 4 & 5

Deductive: Backwards from EU resale price.
Computed: Cost of production + profit. Essential for complex supply chains.


2. Transfer Pricing Reconciliation

We bridge the gap between OECD (Direct Tax) and WCO (Customs) guidelines. The misalignment often triggers audits.

TP Adjustment Type Customs Impact (WCO) Strategic Action
Upward (Debit Note) Undervaluation Risk Voluntary Disclosure (Ravvedimento) to pay delta duties without full penalties.
Downward (Credit Note) Duty Overpayment Refund Claim (Art. 116 UCC). Requires "Formula Pricing" clause in contract (Hamamatsu).

3. Hidden Value: Assists & Royalties

Assists (Apporti): Molds, tools, and engineering/design work done outside the EU and provided free of charge to the producer must be added to the customs value.

Royalties: Dutiable only if they pass the "Condition of Sale" test. We review license agreements to exclude reproduction rights and buying commissions.

Royalty Dutiability Check
Related to Goods?
Condition of Sale?
Add to Customs Value (Art. 71 UCC)