Brazil: RFB clarifies Transfer pricing rules on import of products

September 04, 2018

On 30 august 2018, the Department of Federal Revenue of Brazil (RFB) published a ‘Private Ruling 95/2018’ in the Official Gazette which clarifies the calculation of price parameter on import of steel product for resale. Under this Private Ruling

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Indian APA accepts customs valuation as arm’s length price for transfer pricing

March 23, 2018

Recently, the Central Board of Direct Taxes (CBDT) has entered into an advance pricing agreement (APA) where the price determined by the Indian Customs authorities was accepted as arm’s length price for import transactions for transfer pricing

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India: The Tribunal considers the AMP costs to be the customs value of the transaction

February 28, 2018

The Delhi Customs Excise & Service Tax Appellate Tribunal (CESTAT) in a recent case, upheld the AMP (Advertisement, Marketing and Promotion) expenses to the transaction value declared for customs purposes. In that case, the appellant was a

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Japan issues guidance concerning customs valuation opinion

July 20, 2017

Japan’s customs bureau has recently issued guidance “customs valuation opinion” concerning how retroactive transfer price adjustments are to be addressed from a customs valuation perspective. The customs agency will consider adjustments as

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