Chapter X of the 2022 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“OECD Guidelines”) and the 2022 Dutch Transfer Pricing Decree contain extensive guidance for financial transactions. Before the update in 2022, the OECD Guidelines contained little to no guidance on financial transactions.
The general rules for determining the customs value are laid down in the Union Customs Code (UCC). The term ‘customs value’ is primarily used when applying the customs tariff. The UCC has six methods for determination the value, which should be applied in chronological order (at the request of the importer methods 4 and 5 are interchangeable).
The origin of a product is essential for the technical customs treatment of goods that are imported into or manufactured in the European Union (EU), or for goods that are exported to third countries. There are two definitions of the term ‘origin’: the preferential origin and the non-preferential origin.
The ongoing public debate about transfer pricing, transparency in taxation and the levying of tax where value is created within a group has increased the pressure for regulatory action. This has resulted in the introduction of various laws and regulations on a global, regional and local level.