A Study of the Customer Valuation System and International Harmonization of the Transfer Pricing Taxation System

Abstract

Purpose - This research is based on international trends and the U.S. response to problems caused by the overlap of the tariff evaluation system and the transfer price tax system. This study intends to review the existence of the domestic tariff evaluation system and transfer price tax system. Design/Methodology/Approach - In this study, only the upper transfer price adjustment, which leads to the collection of tariffs, is considered in the customs evaluation system, and the discussion was conducted with a sense of the current situation in which taxpayers are unilaterally disadvantaged. To this end, after analyzing international trends in problems caused by the overlap of the tariff evaluation system and the transfer price tax system, a new method of Korea's tariff evaluation system and transfer price tax system was proposed. Findings - As a result of analyzing discussions by the World Customs Organization (WCO), the International Chamber of Commerce (ICC), and the Organization for Economic Cooperation and Development (OECD), it is desirable to consider a transfer price adjustment in the tariff evaluation system. However, since it is clear that compensation adjustments or some price adjustments affect the tariff evaluation system, it is very important to clarify that effect in the relevant guidelines. Research Implications - Currently, it can be said that the correction disposition by the transfer price tax system in Korea does not affect the tariff evaluation system. However, since it is clear that compensation adjustments or some price adjustments affect the tariff evaluation system, it is important to clarify that effect in the relevant guidelines.