Bridging US customs and transfer pricing requirements

Rebel Curd and Robin Hart of CRA’s Transfer Pricing Practice were engaged to prepare an analysis and report that bridges income tax and customs requirements for the intra-group importation of finished consumer goods from Mexico, Australia, and the United Kingdom. We took into account US Treasury Regulations Section 1.482, US Customs Code 19 USC 1401a(a), and US Federal Regulation 19 CFR 152.100-152.108. Our analysis involved the use of the comparable uncontrolled price method and the comparable profits method for transfer pricing purposes and circumstances of sale tests 2 and 3 under the transaction value approach for customs purposes.