Japan’s customs bureau has issued guidance concerning how retroactive transfer price adjustments are to be addressed from a customs valuation perspective.
The guidance about the customs valuation treatment of retroactive transfer price adjustments was issued as a “customs valuation opinion” (June 2017) on the question and answer (Q&A) section of the customs authority’s website.
The guidance opinion was in response to a specific importer inquiry, with the customs authority determining that the specific adjustments are to be considered part of the value declared to Japan’s customs agency. The determination was based on provisions contained within the sales contract between the importer and related foreign supplier and an advanced pricing agreement (APA) between the importer and the bilateral tax authority (that stipulates, in part, that the sales prices for the products to be imported are subject to review and adjustment after payment is made).
The customs agency further stated that the adjustments would be considered part of the customs value, whether the adjustments were upward or downward.
For more information, contact a professional with KPMG’s Trade & Customs practice in Japan:
Masaharu Umetsuji | +81 3 6229 8070 | firstname.lastname@example.org
Kozu Takayuki | +81 3 6229 8205 | email@example.com
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