Related-party transactions require demonstrating that the relationship did not influence the price. CBP’s arms-length tests: comparable transaction value test, deductive value test, computed value test. Transfer pricing for tax purposes and customs valuation interact but are separate; alignment required.
This guide covers Related-Party Valuation. Specialty customs topics range from valuation methodology to specific cargo types and regulatory overlays.
Practical implementation depends on company size, sector, and operational structure.
Definition of related parties
Common ownership over 5%, family relationships, partnership, employer-employee. 19 CFR 152.102.
CBP arms-length tests
Comparable transaction value, deductive value, computed value. Each test has specific thresholds.
Transfer pricing alignment
Tax TP and customs valuation should align. Misalignment creates exposure on both sides.
Documentation requirements
Pricing studies, comparable transactions, financial substantiation. Update annually.
Frequently asked questions
When does this apply?
Most relevant for SMB importers in the named sector or facing the named situation.
What documentation matters?
Standard CBP forms, supplier certificates, BOM analysis, and topic-specific records.
What is the timeline?
Initial assessment 2-4 weeks; full implementation 8-16 weeks depending on scope.
What does this cost?
Project work $5,000-$25,000 depending on complexity. Ongoing retainer for active operations.
How do I begin?
Book a 15-minute scoping call. We confirm fit before any engagement.
Get started
Engage on a specific specialty topic. Project pricing varies by scope.