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Coexistence of Customs Valuation Transaction Value Method and Transfer Pricing Transactional Net Margin Method in Multinational Enterprises Importing Goods from Switzerland to Germany

Title: Coexistence of Customs Valuation Transaction Value Method and Transfer Pricing Transactional Net Margin Method in Multinational Enterprises Importing Goods from Switzerland to Germany

Master's Thesis , 2024 , 108 Pages , Grade: 1.3

Autor:in: Sergo Dreving (Author)

Law - Tax / Fiscal Law
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Summary Details

The master's thesis explores the complex relationship between Transfer Pricing (TP) and Customs Valuation (CV) in multinational enterprises (MNEs), focusing on the compatibility of the Transactional Net Margin Method (TNMM) and the Transaction Value (TV) method.

Using a legal framework analysis, the study examines regulatory overlaps and conflicts, particularly in the context of tangible goods imported from Switzerland to Germany.

The research highlights the impact of retrospective TP adjustments on customs values and assesses whether a harmonised approach to TP and CV is legally and practically feasible.

The findings suggest that, despite their distinct objectives, both disciplines can be reconciled through proactive compliance strategies, integrated documentation, and regulatory engagement.

The thesis provides practical recommendations for MNEs, offering a structured framework to navigate these dual regulatory environments while considering administrative practices and relevant case law.

Details

Title
Coexistence of Customs Valuation Transaction Value Method and Transfer Pricing Transactional Net Margin Method in Multinational Enterprises Importing Goods from Switzerland to Germany
College
University of Münster  (Faculty of Law)
Grade
1.3
Author
Sergo Dreving (Author)
Publication Year
2024
Pages
108
Catalog Number
V1563436
ISBN (PDF)
9783389113097
ISBN (Book)
9783389113103
Language
English
Tags
Customs valuation Zollwertermittlung Transfer pricing TNMM Transactional net margin method Transaction value method Arm's length principle Interplay Harmonious coexistence Customs Taxation Direct taxation Switzerland Germany EU European Union UCC Transfer pricing adjustments TP
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Quote paper
Sergo Dreving (Author), 2024, Coexistence of Customs Valuation Transaction Value Method and Transfer Pricing Transactional Net Margin Method in Multinational Enterprises Importing Goods from Switzerland to Germany, Munich, GRIN Verlag, https://www.grin.com/document/1563436
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Excerpt from  108  pages
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