ࡱ> kmj )SbjbjcTcT 4x>>K 88{{{{{8l3,E#_____:::"""""""$)%':"{:::::"{{__":^{_{_":"r(!T("_IPmR|!"#0E#!((("({(":::::::"":::E#::::(:::::::::8 A: Transfer Pricing Adjustments A world of difference? The reality of modern international trade is that many elements of a transaction may not be determinable at the time the merchandise is entered. For example, the final value of merchandise sold between related parties may, due to transfer pricing arrangements, not be known until the close of an accounting period, so the correct, final value of the merchandise is not known until that time. As a result, retroactive adjustments of transfer pricing between related parties has become increasingly prevalent, especially in trade by parties trading between the US and the EU. There is a general awareness of the impact of transfer pricing adjustments on prices for corporate tax purposes. The impact on customs duty due on those goods that are imported is less well known. In addition to this overall lack of awareness, there is a marked disparity between the treatment of transfer pricing adjustments for customs duty purposes between the EU and the US. In this article, we will outline the treatment of such adjustments in the EU, and the UK in particular, as well as exploring the differences between the customs authoritys treatment of these adjustments in the EU and the US. Common Principles EU import valuation principles are consistent with the U.S. in that they are both based on World Trade Organization valuation guidelines and methods of appraisal of duty. As is well widely known, the EU is a customs union, which requires all member states to operate uniform customs legislation; this is achieved by the adoption of European Commission (EC) regulations. Such regulations are directly applicable in all 27 member states. EC legislation is therefore directly implemented in all Member States without recourse to domestic legislation, except for punitive action, which is outside the EUs remit and therefore requires domestic legislation. Treatment of Transfer Pricing Adjustments In the US, transfer pricing adjustments are managed via the U.S. Customs' Reconciliation Prototype Program (Reconciliation). This process allows the importer, to file summaries with of import entries Customs and Border Protection (CBP) with the best available information at that time with the mutual understanding that certain elements of the declaration, such as the declared value, remain outstanding. At a later date, when the specifics have been determined, the importer files a Reconciliation which provides the final and correct information regarding the import transaction(s). The Reconciliation is then liquidated or completed, with a single demand for duty or a refund of duty, as appropriate However, the EU and its member states do not have a formal common process for reporting value adjustments that are unknown or unknowable at the time of entry. The US Customs and Border Protection (CBP) agency, on the other hand, have a long standing, formalised process for managing pricing adjustments. So, in addition to considering the legislative structure affecting transfer pricing adjustments, any procedural aspects of these adjustments also need to be considered; these will be the only aspects which could result in different requirements or approach. The same principle applies to any penalty action which could result from failure to disclose any transfer pricing adjustments. EU Valuation law The basic legislation which currently control European customs procedures are: Commission Regulation 2913/92/EEC the Community Customs Code (CCC); and Commission Regulation 2454/93/EEC the Implementing Regulation (CCIP). The international rules on customs valuation, set out in the WTO Customs Valuation Agreement, have been translated into EU customs legislation in: Articles 28 to 36 to the CCC; and Articles 141 to 181a and annexes 23 to 29 to the CCIP. All goods imported into the EC are subject to the appraisal of the correct value for duty purposes based on the CIF (Cost, Insurance, and Freight) value of the goods; it is the Customs authorities responsibility to determine the final duty amount. The customs authorities final appraisal and assessment of duty occurs after the importer, using all reasonable care, has declared the value of the goods to the Customs authority. The CCC establishes the rules for the appraisal of imported goods and provides six different methods of valuation, which are based on the rules set out in the WTO Customs Valuation Agreement, which have been transposed into the directly applicable European Community customs legislation. The rules applicable in the EU in regard to valuation are identical to those methods of appraisement applied in the US. The six methods have to be considered in strict hierarchal order. Generally, the value of all goods imported into the EC is the transaction value the price paid or payable for the goods; otherwise known as Method 1. In the event the goods cannot be appraised on the basis of transaction value, the alternative methods are to be considered in their hierarchal order: Transaction Value of identical goods (Method 2) Transaction Value of similar goods (Method 3) Deductive Value (Method 4) Computed Value (Method 5) Fall back method (Method 6) (The importer may request the reversal of Deductive Value (Method 4) and Computed Value (Method 5)). Consistent with the interpretation of customs valuation principles in the US, under EU valuation rules, a relationship between buyer and seller in and of itself should not lead to a rejection of a customs value based on a transaction value. However, it is possible for customs authorities to request information to make sure the price is at arms length. Therefore, in a related party situation where Method 1 is utilised the importer should be ready to demonstrate that: the price is consistent with normal pricing practices in the sector, the price corresponds to prices by the seller to unrelated buyers, or the price is adequate to cover all costs and a reasonable profit margin. If none of these are the case, the transaction value could be rejected. If none of these tests can be applied the transaction value could be rejected by the customs authorities. As outlined above, all law concerning customs value is EU based. The existing law, as it relates to customs valuations matters, does not contain any specific provision for the treatment of Transfer Pricing Adjustments. Furthermore, there is no comparable, formally recognised process, to the US Reconciliation in the EU to allow EU importers to electronically flag the provisional nature of the import value and provide an aggregate post-entry value adjustment for multiple import transactions in a single filing. There are no precedents or specific reasons for the absence of such a program save that EU customs law requires the Member States to develop procedures for the acceptance of import declarations. Instead, the EU and its Member States rely on one of the basic principles of WTO valuation methodology in its management of Transfer Pricing Adjustments; the definition of transaction value. This is laid down in Article 29 to the CCC. Specific definitions and requirements are laid down in Article 29.1 and Article 29.3(a), which states: Article 29 The customs value of imported goods shall be the transaction value, that is, the price actually paid or payable for the goods when sold for export to the customs territory of the Community, adjusted, where necessary... Article 29.3(a) The price actually paid or payable is the total payment made or to be made by the buyer to or for the benefit of the seller for the imported goods and includes all payments made or to be made as a condition of sale of the imported goods by the buyer to the seller or by the buyer to a third party to satisfy an obligation of the seller. The payment need not necessarily take the form of a transfer of money. Payment may be made by way of letters of credit or negotiable instrument and may be made directly or indirectly. When considering the conditions laid out in Article 29, one also needs to be cognisant of the law relating to the declaration of imported merchandise. These provisions, insofar as they relate to valuation matters, are laid out in Chapter 2, Section 1 of the CCIP which covers Incomplete Declarations and specifically the second indent to Article 254 of the CCIP. This states that: - where the goods are liable to ad valorem duties, their value for customs purposes, or, where it appears that the declarant is not in a position to declare this value, a provisional indication of value which is considered acceptable by the customs authorities, due account being taken in particular of the information available to the declarant, Pursuant to Article 29.1 and Article 29.3(a), and in the absence of a comparable process to the US Reconciliation, the obligation is on the importer to regularise the customs value where retroactive transfer pricing adjustments are made that impact the value declared on past imports transactions. When such adjustments are made, the original entry will be deemed to be incomplete under the provisions of Article 254 CCIP. Regularising action Retrospective adjustments may be made that relate to the correct amount of duty liable on the imported merchandise. Such retrospective adjustments usually manifest themselves in relation to the product classification or valuation. Transfer pricing adjustments fall into this category by virtue of the legal provisions outlined above together with the provisions allowing the customs authorities to revise import entries retrospectively. Under US Reconciliation, the use of this program is mandatory for the significant majority of US importers; the main exception being that importers can still adjust on an entry-by-entry basis. In the absence of a formal process under EU legislation and UK procedure, the retrospective amendment of import entries is confirmed in Article 78. 3 to the CCC, which states: Where revision of the declaration or post-clearance examination indicates that the provisions governing the customs procedure concerned have been applied on the basis of incorrect or incomplete information, the customs authorities shall, in accordance with any provisions laid down, take the measures necessary to regularize the situation, taking account of the new information available to them. The period of retrospective action is a maximum of three years. The regularising process can take a number of forms but, essentially, it distils into two basic options. The first option would be to agree with the relevant customs authority that the price of merchandise is to be reviewed on an annual basis and that import entries are made on a provisional basis, which will usually require security being lodged with the customs authorities. The alternative option is to make the customs authorities aware that transfer pricing adjustments could be made, make full entry at the time of import and notifying the customs authorities when adjustments are made. This second approach is usually accepted by the customs authorities as the appropriate method of accounting for transfer pricing adjustments when regular reviews are conducted and communicated to the authorities. Whilst this may seem to be relatively straightforward, the reality is, however, not. HMRC treatment of Transfer Pricing Adjustments The theory of regularising the impact of transfer pricing adjustments, as outlined above, is sound and legislatively supported. However, the practical realities of the treatment of such adjustments can differ significantly. The core issue influencing the practical treatment of these adjustments is the contractual position of trade between the parties. In broad terms, the customs authorities consider the position to be thus. Situations may arise, where, for a variety of reasons, the price paid to the seller for the imported goods is revised or re-negotiated after the entry of the merchandise. Where, at the time of entry, there are contractual arrangements in place between the buyer and the seller indicating the possibility of retrospective price adjustments, the invoice price for the goods concerned would, in effect, be provisional. This means that a final value cannot be determined for customs duty at the time of entry. Retrospective Price Increases Where there has been a retrospective price increase the situation is often very clear-cut. In most cases, HMRC will treat such increases as part of the total payment made by the buyer to the seller for the imported merchandise. The fact that the buyer agrees to pay an increased price is regarded as confirmation that the contractual arrangements implied, or there was an implicit understanding between the parties that such an adjustment may occur, when the goods were ordered or purchased. When the authorities are aware of upwards adjustments, they will issue a demand for the additional duty (and import VAT where appropriate) for the underpayment of duty. In many cases, this will be the result of little evaluation of the circumstances by HMRC. Retrospective Prices Reductions Where there has been a retrospective price reduction, the importer may submit a claim for a refund of duty originally paid on the higher value. Such claims must be accompanied by evidence including full details of the contractual arrangements as well as rebates received from, and credits notes issued by, the seller. The key item of evidence here is the contract between the buyer and the seller. Whilst EU customs law acknowledges that contracts may be verbal as well as written, they will almost certainly seek alternative evidence, for example reports of meetings, correspondence, etc between the buyer/importer and the foreign seller to confirm the position. Where such evidence does not exist or doubt remains as to veracity of the situation, the customs authorities may seek an affidavit from the parties to the verbal contract. Where they are satisfied that the price decrease stemmed from contractual arrangements in force at, or prior to the time of entry of the goods concerned to, free circulation, an appropriate refund of duty will be made (subject to the rules regarding duty refunds). Declarations of any adjustment should be made within 3 years from the date of each relevant entry. This is the statutory limit in which import entries can be impacted by retrospective changes. As can be seen from the foregoing, HMRCs treatment of price reductions can be very different from price increase where there is no contract or agreement between the parties for such adjustments. Indeed, the most revealing indication of this is to be found in HMRCs internal guidance on the issue of retroactive price reductions. For completeness the relevant section is repeated here verbatim. 3.7.5 Retrospective price adjustment In cases where, either Customs consider that the trading arrangements do not provide for a retrospective price adjustment or no contractual arrangements exist but the price is adjusted upwards retrospectively, Customs will take action to collect arrears of duty and import VAT. The fact that the buyer agrees to pay such a price increase is regarded by Customs as confirmation that there was an implicit understanding between the buyer and the seller when the goods were ordered or purchased (that is, prior to entry to free circulation) that such an adjustment may occur. In similar circumstances but where the price is adjusted downwards, the importer may submit a claim for a refund of duty. Such claims will be regarded as being the result of post-importation bargaining out with any contractual arrangements. Thus the claims will be rejected by Customs. In effect, if there is an upwards price adjustment, resulting in underpaid duty, HMRC will issue a demand for duty even in the absence of a contract between the parties. However, their treatment of duty refund claims in similar circumstances is startlingly different. As can be seen from the above, and common with most customs authorities reaction to change, the disclosure of retrospective price adjustments that are not pre-advised to the customs authorities, and are not subject to a contractual agreement between the parties, could open the possibility of an in depth examination of pricing between the parties. The basis of this would be the potential interpretation that the price change is an indication that the relationship between the buyer and the seller does affect the price charged for goods and is not arms length as a result. Such an investigation would not automatically compromise the arms length nature of the pricing or disallow the prices used. The pricing arrangement would stand or fall on its robustness. It would be highly unusual for penalties to be imposed where a disclosure is made voluntarily. Where such changes are discovered by the customs authorities themselves, the customs authorities may impose penalties for non-disclosure. Declaration of Transfer Pricing Adjustments In the absence of a procedure to account for transfer pricing adjustments we advocate that adjustments that impact the customs value of should be declared to the customs authorities without exception. Advising the customs authorities in advance of imports that such retrospective adjustments can or will be made is also advisable as it smoothes the way for the adjustments to be accepted by the relevant authorities; especially for reductions in value. Additionally, making a voluntary disclosure will, in most cases, result in no penalty action by the respective customs authority. In the unlikely event of penalties being imposed they will be minimised by the voluntary disclosure. However, where pre-advised adjustments or post-import voluntary declarations are not made, and the customs authorities discover that adjustments have been made and have not been declared to them during the course of post import checks, a duty demand will result. HMRC will also consider civil penalty action under the The Customs (Contravention of a Relevant Rule) Regulations 2003. Where a US seller participates in the U.S. Reconciliation, ignorance of the impact retrospective adjustments could have on the customs value of imported goods would be difficult to justify. In such circumstances the local customs authorities may be more likely to assess penalties. Conclusion This whole area continues to develop as transfer pricing techniques and agreements mature. The appreciation of the impact of retroactive adjustments have on the duty payable on imported merchandise still lags behind somewhat. When importers realise transfer pricing adjustments impact on customs duty as well as direct taxation the question is more than likely to be to declare of not to declare. The unfortunate truth is that, in many cases, the customs duty impact on retroactive price increases can often be negative. 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