Harmonizing Revenue Realms: The Entangled Facet of Income Tax and Customs Valuation
The intersection of income tax and customs valuation is a crucial aspect for businesses and tax authorities. This article delves into the intricacies of these two realms, offering insights and guidelines for achieving consistency in their application.
The price at which related entities transact should be of interest to both taxpayers and revenue authorities. While the Customs Authorities keep an eye on the transaction price between related entities to make sure that price is not understated in order to reduce the duty payable on importation of goods, the Income-tax Authorities, through their Transfer Pricing wing, examine the transaction price to make sure that the profit as well as the tax payable on the profit earned from the goods imported is understated. This article tries to illustrate a few features of how Income Tax and Customs interact when valuing products and to offer a few guidelines for ensuring consistency in the exchange rates between the parties. Additionally, contrasts the domestic perspective with regard to transfer pricing and custom value, as well as its complexities in international trade and the juggling act between the authorities.
Nowadays, inter-company transactions account for more than 60% of the market. For income tax reasons, companies that engage in cross-border commerce must abide by the transfer pricing (“TP”) laws and reconcile the transfer pricing adjustment with the customs value. Under the conventional customs approach, such a reconciliation is exceedingly difficult. The contemporary method calls for integrating the TP documentation with a part specifically for customs, starting an open dialogue with the customs services, and concluding an agreement. Applying the best reconciliation to reduce administrative costs and eliminate any danger of sanctions in the international market would be the best method to establish an efficient TP/customs procedure in any country affected by the application of the TP policy.[1]
Undoubtedly one of the trickiest challenges to handle while crossing a border is the accurate estimation of the customs value. Along with the origin and categorization of products, the valuation of goods is one of the three core concepts in customs law. Indian law provides a closed set of procedures for calculating the customs value, whose application may be rigidly hierarchical, with a view to establishing the amount of duty owing (Valuation Methodologies).[2] The term “importation/purchase” in the context of cross-border transactions is important for both direct taxation and customs duties that the buyer must pay. This is crucial in relation to the transfer pricing concerns raised by a transaction involving a related party. In reality, a transfer pricing analysis is required in cases where separate businesses from the same group are situated in different nations in order to ensure that the transactions are not intended to transfer profits to those nations (especially with low-taxation systems).[3]
In contrast to what has previously happened in the area of customs, neither the OECD countries nor EU Member States have started a process for harmonizing direct taxation, resulting in profits being taxed under separate laws and at different rates. In this regard, it should be noted that, notwithstanding the importance of valuing the debt for direct taxes and customs duties in foreign transactions, the necessary values may vary quite noticeably depending on the applicable laws. More precisely, when it comes to direct taxation, transfer pricing practices that are connected to the calculation of the customs value must be taken into consideration.[4]
The international community makes reference to the OECD Transfer Pricing Guidelines, which were initially published in 1979. Although these guidelines are not mandatory, they are followed by businesses and tax authorities in every OECD nation. The Customs Valuation Agreement was ratified by the World Trade Organization (“WTO”) in the same year[5]. However, in this instance, Community customs law refers to pertinent principles nearly slavishly. Article VII of the General Agreement on Tariffs and Trade (“GATT”) on customs valuation served as the model for the Code’s rules dealing to customs value. According to the WTO Agreement on Customs Valuation, Customs handles the issue of Transfer Pricing through restrictions on Related Party Transactions. Articles 1.1(d), 1.2(a) & (b), and 15 of the WTO Value Code elaborate on the customs valuation treatment of related party transactions. Although Article VII of the GATT and the WTO Agreement on Customs Valuation does not specifically include transfer pricing, they do implicitly accept the “arm’s length concept” in the context of related party transactions.[6]
The tax rates in various nations fluctuate significantly. These variations encourage multinational corporations to move profits from nations with high tax rates to those with lower tax rates. Internal transactions, a holding company providing financing or consulting services to its subsidiaries, a manufacturing branch supplying finished goods to a distributing branch, or one associated enterprise supplying service provision to another are all simple ways to achieve this shifting of profits. The MNEs have the power to determine the transaction’s pricing and terms, which might affect the profit margin and subsequent tax liability. The arm’s length concept, found in Article 9 of the OECD Model Convention, was developed by tax administrations (organized in the OECD) to stop this from happening and mandates that controlled transactions be carried out at market prices. According to this definition, the arm’s length principle states that “entities that are related through management, control, or capital in their controlled transactions should agree the same terms and conditions that would have been agreed between non-related entities for comparable uncontrolled transactions.” If this tenet is upheld, it can be said that the specific transaction’s terms and conditions are ‘at arm’s length.[7]
However, numerous nations, including the United States, the United Kingdom, Germany, Australia, Canada, and France, have already established explicit measures in their national laws and administrative processes to control transfer pricing activities. In order to ensure adherence to the arm’s length price principle, these measures are primarily based on the OECD guidelines for examining pricing patterns in international transactions between related parties. According to a ruling made by the US Customs Service in 2000, a bilateral Advance Pricing Agreement (“APA”) describing a method of establishing transfer prices between a taxpayer importer and related parties may be taken into consideration when determining whether the transfer prices constitute Transaction value for the purposes of valuing related party transactions under US Customs Law. In order to prevent US importers from endangering government revenue by valuing goods inconsistently for Customs and Income Tax purposes, Section 1059 A has been introduced in the US. Importers are prohibited by Section 1059A from declaring a transfer price that is higher than the value disclosed for Customs valuation purposes[8]. Working Arrangement for Mutual Assistance and Exchange of Information Between the U.S. Customs and the IRS has been signed. Regarding Compliance and importation concerns” (the Mutual Assistance Agreement), a document created by the Department of Treasury, the U.S. Customs Service, and the Internal Revenue Service. The topic of transfer pricing raises difficult concerns for both the tax and customs authorities as well as the global trading groups[9].
The primary distinction between customs and income tax authorities is that the former aggressively work to increase the value of imported goods through transfer pricing adjustments, whereas the latter aggressively work to decrease the value of imported goods through customs duties. This is because the higher the value of the goods imported, the higher the customs duty liability (lower transfer price will result in higher taxable profits in India).[10]
The Indian Income Tax Act, 1961’s Sections 92 to 92F list the Transfer Pricing Laws, which apply to cross-border transactions within groups of companies. The arm’s length price concept must be used to determine the income resulting from international transactions or specified domestic transactions between Associated Enterprises (“AE”). TPR was introduced with the intention of providing a comprehensive legal framework that can result in the computation of reasonable, fair, and equitable profits and taxes in India for multinational enterprises. Additionally, new sections 92A to 92F of the Act were added to address the computation of income from an international transaction with consideration for the arm’s length price, the definition of associated enterprise, the definition of international transaction, the computation of arm’s length price, and the main purpose of the international transaction. The TPR’s underlying legislative goal is to prevent profit shifting through pricing manipulation in cross-border transactions, which would erode India’s tax base. The purpose of the TPR, according to the explanatory document of the Finance Bill, 2001, was to stop improper transfer pricing practices.
The objective of both transfer pricing and customs valuation methodologies is to determine whether or not the price at which the transaction has been entered into has been influenced by the relationship between the parties entering into the transaction. This is where the two methodologies are similar. The methodologies outlined in the Income Tax Act and the Customs Valuation Rules also share a lot in common. For instance, the Deductive value method [Rule 7 of the Customs Valuation Rules] prescribed under the Customs Valuation Rules can be compared to the Resale Price Method under the Income Tax Act because both use the sale price of the imported goods to an unrelated party as the starting point and work backwards to arrive at the comparative price/value [Section 92C(1) of the Income Tax Act read with Rule 10B(1)(b) of the Income Tax Rules].
The transfer pricing rules, however, are different from those governing customs. The functions performed, assets employed, and risks assumed (collectively referred to as “FAR”) by each party in connection with the international transaction must be taken into account when choosing comparable uncontrolled transactions for carrying out the comparability analysis under the TP regulations [Rule 10B(2) of the Income Tax Rules]. The arm’s length price evaluation aims to determine if the parties to the transactions are fairly compensated in light of the FAR analysis. However, when determining the transaction value using any of the techniques outlined in the Customs Valuation Rules, FAR analysis is not a factor.
The TP regulations allows making economic adjustments, such as those for working capital, capacity utilization, etc., between the transactions being compared [Rule 10B(3) of the Income Tax Rules]. Adjustments are also allowed under the Customs Valuation Rules, however they must be made in accordance with certain criteria, such as commission/brokerage, container costs, packing costs, etc. The TP provisions allow the use of the arithmetic mean [Proviso to Section 92C(2) of the Income Tax Act] / range [Rule 10CA(4) of the Income Tax Rules] (35th and 65th percentile when six or more comparable prices are available) where there are several prices when computing the arm’s length price. However, according to Rules 4 and 5 of the Customs Valuation Rules, the lowest value may be used for determining the transaction value of identical or similar products. When data for the accounting year is not available, TP provisions allow use of multi-year data of comparable uncontrolled transactions [Rule 10B(5) of the Income Tax Rules]. According to the Customs Valuation Rules, the transaction value of identical or comparable products imported at the same time as the commodities being assessed may be taken into account for determining the value of those goods.
The Income Tax Act allows for the application of the most appropriate transfer pricing method, whereas the Customs Valuation Rules require that the hierarchy of the valuation method be followed after the declared value is rejected. Both systems have a number of characteristics, hence efforts should be made at the national level to coordinate the strategies. The identical/similar goods technique, deductive value method, and computed value method under the Customs Valuation Rules are quite similar to the first three methods of the Income Tax Act, which are (a) Comparable Uncontrolled Price method, (b) resale price method, and (c) cost plus method.
The Mumbai and Chennai Tribunals concluded in Serdia Pharamaceuticals[11] (India) Private Limited, Mobis India Limited[12], and Fuchs Lubricants (India) Pvt Ltd,[13] that the valuations made by the Customs authority cannot be taken into consideration for. However, in the case of Coastal Energy Pvt Ltd,[14] the Chennai Tribunal made the decision to differ from the aforementioned viewpoints. Based on information from customs authorities, the TPO concluded that the taxpayer had overstated its purchase price and accordingly made an adjustment for the price difference. The taxpayer in this case had imported 1,000 MT of coal from its AEs at a cost of 46.51 USD per MT, but the TPO discovered that another company had imported 1440 MT of coal at a cost of 43 USD per MT. The Dispute Resolution Panel concurred with this and affirmed it. The taxpayer argued that the customs officials’ valuation was unrealistic in an appeal before the Tribunal. In this regard, the Tribunal ruled that the customs authorities are in charge of determining a fair assessment value for the imported items and do so based on scientifically developed methodologies[15]. The customs authorities did not make an arbitrary decision when they valued the goods. The Tribunal continued by pointing out that the assessee might prove its case for a price other than the customs price as long as suitable materials were produced to back up its claims. The Tribunal affirmed the TPO’s decision to use the customs valuation as the arm’s length price for TP purposes, as a result[16].
There may be quantity-related discounts on account of which there would have been a lesser price paid in the comparable uncontrolled transaction, and adjustments for the same could be made under TP regulations in order to render the price comparable. It can be noted in the decision of Coastal Energy Pvt Ltd that the quantity imported from AEs is 1000 MT while the quantity imported in the comparable uncontrolled transaction was 1440 MT. The assessee in the instance before the Tribunal has not raised this issue. M/s Panasonic Consumer India Pvt. Ltd. Ltd., the assessee in this instance, had based their decision on the valuation that the Customs Department had approved, a figure that the TPO and the DRP had contested and ignored. The Delhi ITAT ruled that different standards are applied under Chapter X of the Income-tax Act and Customs valuation for distinct purposes. Fuchs Lubricants (India) Pvt. has likewise upheld similar ideals. both Mobis India Ltd. and Ltd[17] (Mumbai ITAT) (Chandigarh). In the case of Tianjin Tianshi Biological Development Company Ltd., the AO obtained information from the Customs authorities and adjusted for the discrepancy between the value of the company’s actual sales to its Indian-related party Tianjin India and the value of the Maximum Retail Price (MRP) declared to custom authorities. The adjustment was sustained by the DRP. The Assessee had argued that, notwithstanding the fact that the assessee must pay import duty based on MRP, the idea of MRP is a legal fiction developed particularly for the purposes of section 4A of the Excise Act, read with section 3 of the Custom Act and the Standard Weight & Measures Act. The Central Excise Act and the Customs Act formed a legal fiction that offers a measure for the levy of excise/custom duty, which cannot be followed or imported to the Income-tax Act, according to the Delhi ITAT’s decision in favor of the Assessee. The assessee and the TPO relied on customs valuation in the aforementioned circumstances[18]. The Tribunal, however, disallowed the reliance on customs valuation, holding that the Income-tax Act’s transfer pricing regulations, which are separately coded, must be observed.
Based on the aforementioned legal precedents, it should be emphasized that almost all tribunals have supported the idea that the methodology outlined in the TP regulations and the Customs values are distinct from one another and unique in their own right. As a result, it’s possible that the valuation under the two regulations isn’t comparable.
Consequential impact for other taxes
Transfer pricing modifications that have indirect tax ramifications are governed by separate laws and are not subject to the ITA. The basic foundation for valuing supplies for the purposes of calculating the GST liability is the transaction value between the parties, according to the Goods and Service Tax (GST) legislation, which apply to all supplies of goods and services in India (including imports). However, the transaction amount is rejected when it involves a related party. The open market value (OMV) of identical products or services provided to an unrelated party is one of the rules that must be used to benchmark a related-party transaction. If no such OMV is available, the taxable value shall be determined, in the order listed above, by reference to the value of comparable supplies, the cost construction technique, or the price at which the items were sold to independent third parties.
Insofar as assessing the taxable value for the purposes of customs duties is concerned, Indian customs legislation, which allows for the levying of import and export charges on commodities imported into and exported from India, is based on the Customs Valuation Agreement of the World Trade Organization. Based on the same, the declared import price is not accepted in cases of related-party transactions unless it can be proven that the relationship between the buyer and the seller did not “affect the price” of the imported products. In the absence of such evidence, the transaction value is rejected, and the imports’ valuation is administratively submitted to Customs’ Special Valuation Branch (SVB)[19]. To calculate the arm’s-length transaction value, the SVB progressively applies the valuation principles outlined in the Customs Valuation Rules. According to the Customs Valuation Rules, this value is calculated using the deductive value technique or computed value method, followed by the residual method, based on the import value of identical or similarly-priced items (with any necessary changes).
Attraction of Inevitable Double taxation
Overpayment will occur for the taxpayer if the customs agency and tax administration apply their rules independently. When a retrospective downward adjustment is made after importation to ensure that the price is fair, the customs administration may not take this into account, and the taxpayer may be required to pay more customs charges on the same batch of import transactions. The fact that this type of “double taxation” results from what appear to be opposing stances taken by the tax and customs authorities can make it more irritating for taxpayers. The tax administration’s enforcement of transfer pricing compliance does not simultaneously ensure customs compliance. In a typical illustration, customs officials do not accept rates established using transfer pricing techniques and do not make backward revisions.[20]
Impacts on taxpayer’s compliance
Multiple similar regulations are brought about by the dual structure’s existence. These are the procedures, rather complex documentation requirements, and audit systems used to calculate import value. Due to the effects of the dual structure, taxpayers are vulnerable to the possibility of several audits and changes. Taxpayers are compelled to choose the option that lowers their tax obligation the most because two sets of regulations are applied to the same transaction without any coordination. Companies can assess whether specific programs are available based on domestic legislation to integrate their commercial and invoicing practices (including price adjustments) within their processes for calculating and declaring the customs value of imported goods in order to avoid lose-lose scenarios. It is unpleasant to be the subject of a tax audit by the customs or tax authorities since it is quite expensive and damaging. It makes sense to follow the rules to a high degree in order to prevent such a confrontation. However, in a contentious situation when taxpayers are looking for relief, choices that are beyond the law may be preferable in actuality.
Advance Pricing Agreement (“APA”) programs are active in a number of nations and have been around for almost 30 years in nations like Canada, the United States, Japan, and the United Kingdom. Such programs’ main objective is to give taxpayers assurance regarding the transfer price of international transactions they conduct with members of their group. Numerous tax issues involving the topic of transfer pricing have arisen as a result of the rapid expansion of international trade through an increasing number of Multi National Enterprises (“MNEs”). An APA is a method for resolving transfer pricing difficulties in advance, or at the very least, prior to the occurrence of a dispute involving a cross-border related party transaction[21]. To avoid any disagreement over transfer pricing, the tax authorities and taxpayers agree in advance on the transfer price of products and services traded between group organizations.
The Finance Act of 2012, which included Sections 92CC and 92CD to the Income-tax Act of 1961, marked the beginning of India’s APA scheme. For international transactions involving Associated Enterprises (AEs), these statutory provisions, which became effective on July 1, 2012, gave the CBDT the legal justification to enter into APAs with taxpayers for a maximum of five years in order to determine the ALP or to specify how the ALP is to be determined. APAs can be multilateral, bilateral (including the CBDT and the tax authorities of one or more nations), or unilateral under the Indian APA program (involving the CBDT only). More than 1150 applications have been submitted in India over the past 7 years. About 82% of these requests are for one-sided APAs between the Indian taxpayer and the CBDT. There have been 271 agreements signed as of March 31st, 2019. (240 unilateral and 31 bilateral).
An APA program, as noted in the Guideline, can help taxpayers by removing uncertainty by improving the predictability of tax treatment in foreign transactions and giving the taxpayers clarity in the tax treatment of the transfer pricing concerns addressed by the APA for a specified term. As a result, a taxpayer could actively seek advance approval of the price in terms of customs and transfer pricing and may prevent potential post-import modifications owing to a joint APA scheme[22]. Beyond this point of agreement, the customs authority’s participation in the APA negotiating process relieves all parties involved by lowering the likelihood of litigation costs and the risk of double taxation. The use of the joint APA raises a number of administrative and procedural problems. For instance, the formation of a negotiation committee, the selection of appropriate techniques, the process for monitoring and evaluation, etc. To resolve the disagreement, those challenges call for a combination of policies, particularly a joint commission that can take on the task of balancing divergent interests.
How to Tackle
The documentation requirements under Income Tax Transfer Pricing Rule 10D are fairly extensive, and they are necessary for the efficient administration of related party transaction valuation and transfer pricing rules. However, there are no precise documentation requirements under Customs legislation. For customs value, transfer pricing documentation, such as the Cost Accountants Certificate provided to the Income Tax Authorities, are highly helpful. There should be a system for automated information transmission in the event that the import value or transfer pricing value changes. In accordance with Rule 10(1)(b) and (c) of the Customs Valuation (Determination of Price of Imported Goods) Rules, 2007, the information regarding royalty payments, general margins of profits, and the cost of technical know-how available with Income Tax authorities will assist Customs in making the necessary additions[23]. For consistency in approach, there should be a system for the automatic transmission of information regarding modifications/revisions made during assessments. Hence, the possible steps are:
- Better communication among the officers in charge of transfer price and custom valuation;
- Information and data sharing between departments with fewer problems;
- Following the alignment of customs and transfer price valuation methodologies, a law modification can create a common advance pricing arrangement.
- Preserving accurate documentation and valuation reports;
- Determine whether the importer and exporter are linked parties or affiliated businesses;
- To arrive at a common value while valuing items, keep in mind both the TP and CV criteria;
- Getting an APA and utilizing it to determine the CV value for upcoming imports.
Conclusion
Multinational corporations and two governmental entities are the main parties involved in the transfer pricing custom valuation overlap. In actuality, each stakeholder is influenced by the other parties’ actions. Therefore, taxpayers are required to abide with both rules; otherwise, they risk being hit with additional taxes, charges, and penalties as well as having to comply with potentially burdensome customs valuation procedures. Therefore, it is crucial to harmonize the two systems in order to avoid market distortion, inconsistent governmental regulations, unfair treatment of taxpayers, and the waste of resources. In essence, the issue being explored in this article arises from a specific circumstance, namely the importation of commodities between connected parties who are situated in several jurisdictions. Since prices must be established twice by the same government for every transaction, this discussion assumes critical importance in terms of efficiency, effectiveness, and market distortion as a portion of international commerce, which is thought to have greatly expanded.
The possibility of a prospective investigation by two government agencies exposes taxpayers to danger. Uncertainty led to a dual structure, decreased the government’s stability and dependability, and disproved the claim that a country is investible. The transaction is governed by customs administration at the time of importation, but from the perspective of direct tax administration, the transaction is governed by tax administration after importation has occurred through retroactive adjustments in which the price applied in the custom entry would change, leading to double taxation because customs rejects the new price. Unfortunately, there is no mechanism in place to reimburse the burden associated with higher customs charges paid as a result of a price alignment.
To guarantee that the overall cash tax is proper and to reduce exposure to fines and interest, management of the customs and transfer pricing tension needs to be done proactive and, when applicable, in partnership with tax authorities. By lowering the amount of uncertainties, improving communication between executive bodies and joining training and conflict resolution groups helps to stabilize the economic climate for both taxpayers and executive bodies. Best practices and peer-based learning are important tools that should be taken seriously. As previously indicated, both sets of regulations demand that “arm’s length” or “fair” values be determined for international transactions involving connected parties and linked businesses. To put it another way, the transfer price must be determined in the same manner regardless of whether the parties are related or not. From this vantage point, it is clear that both sets of rules aim to uphold the same principle by using different methods. Even so, they are not entirely pointless. As a result, two sets of rules express the same objective in two different ways. By expanding chances for stakeholder dialogue, those obstacles might be overcome.
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[2] Doernberg, R. L. (2004). International Taxation in a Nutshell. Thomson/West.
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[11] ITA Nos. 2469/Mum/06, 3032/Mum/07, and 2531/Mum/08.
[12] ITA No. 2112/Mds/2011
[13] ITA No. 6339/Mds/2011
[14] ITA No. 2099/Mds/2011
[15] Hindu Business Line (2006). ‘Customs duty collections will meet Budget estimates’ New Delhi, June 28
[16] Principal Commissioner of Income-tax-5, Chennai v. Redington (India) Ltd (T.C.A. NOS.590 & 591 OF 2019) [2020] 122 taxmann.com. 122 (Madras)
[17] Majumder, S. Dutt (2005). Customs Valuation: Law and Practice. Fifth Edition. CENTAX Publications Pvt. Ltd. New Delhi
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[19] Rajagopalan, TNC (2016). Trade Policy Unclear on Old Goods. Business Standard, April 17
[20] Ramanujam, T.C.A. (2001). How to make Transfer Pricing Effective. Business Line, June 29.
[21] Becker, J., Davies, R., B. and Jakobs, G., 2014. The economics of advance pricing agreements, working paper [online] available at https://www.sbs.ox.ac.uk/sites/default/files/Business_Taxation/Docs/Publications/Working_Papers/ series-14/WP1426.pdf
[22] Lohse, T. and Riedel N., 2012. The impact of transfer pricing regulations on profit shifting within European multinationals, FZID Discussion paper, No. 61-2012, [online] available at https://www.econstor.eu/bitstream/10419/67717/1/732536626.pdf
[23] Sansing, R., 2014. International Transfer Pricing, Foundations and Trends® in Accounting, vol. 9, issues 1, pp.1-57
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