El valor en aduana y los precios de transferencia

Abstract

The purpose of the Transfer Price and Customs Value systems is the determination of the tax basis for the application internal taxes and customs duties. The common ground for both systems are the transactions of goods between related parties. The application of the methods set forth by each of the referred systems may result in different outcomes. Despite the fact that the objectives of both systems are different, there have been convergence efforts from the doctrine and the international legislation (OECD and WCO). However, this issue is still object to debate, which we will intend to clarify through this paper.