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by Atty. Mark Anthony Tamayo

(Last of two parts)
In last week’s article, we discussed briefly the link between transfer pricing (TP) and the customs valuation rules and the possible customs and tax implications of related party transactions.

One of the conditions on the acceptability of a declared value (particularly Method 1 or the Transaction Value of imported goods) for purposes of customs appraisement is that the buyer and the seller must not be related, or if related, such relationship did not influence the price of the goods. The Bureau of Customs (BOC) initially determines whether special treatment arising from a relationship influenced the “price actually paid or payable.” Once the issue is raised, the burden of proving otherwise lies with the importer.

by Atty. Mark Anthony Tamayo

(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.

Both TP and customs valuation rules essentially require that an “arm’s length” or “fair” value (i.e., transfer price between the parties must not be influenced by the relationship or it must be set in the same way as if the parties were not related) be set for cross-border transactions between related parties and associated enterprises.

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Our office address:

15/f Unit A. ACT Tower, H.V. Dela Costa St.
Salcedo Village, Makati City 1227 Philippines

Telefax: +632 831-1297

Telephone: +632 808-5375 • +632 815-0069



Euney Marie J. Mata-Perez

Mark Anthony P. Tamayo

Gerardo Maximo V. Francisco