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Brian Luke Community Blogger, WGRZ-TV

Saturday, September 24, 2011

Request for Advance Public Comments on the Proposed Revocation of Headquarters Ruling Letter ("HRL") 547654 and of Treatment Relating to the Applicability of Transaction Value and Post-Importation Adjustments
(09/23/2011)
Customs and Border Protection (“CBP”) is in the process of re-examining its approach to the applicability of transaction value in the context of post-importation adjustments. Specifically, CBP is asking the public to provide comments on the broadening CBP’s interpretation of what constitutes a “formula” for purposes of using transaction value, thereby allowing post-importation adjustments. In order to permit the orderly administration of these upward and downward post-importation adjustments, CBP is considering modifying prior rulings in order to allow the transaction value basis of appraisement in these circumstances, provided that the importers use the reconciliation program for declaring the value of the affected importations.

Upon review of this matter, CBP is proposing that even though the parties are related and certain costs may be within the control of the parties, if the transfer pricing policy is set before importation and is used by the parties, it may be considered an objective formula, allowing the use of transaction value, provided that certain additional criteria are met. In requesting reconsideration of HRL 547654, the importer described its transfer pricing policy and the distinction between its treatment of variable and fixed costs. According to the policy, none of the variable costs and profits are subject to any post-importation price adjustments. Therefore, the transfer price declared to CBP upon importation is fixed and any fluctuations are not re-invoiced or remitted back to the seller/exporter. The company also provided CBP with a copy of an inter-company memorandum, illustrating how the fixed costs are calculated and set in advance. According to the importer, the fixed costs paid are set; only allocation of those fixed costs to the individual import entries is not fixed until after the month has passed. Pursuant to its transfer pricing policy, the importer seeks to report, via reconciliation, the actual, final amount paid to the Seller for the imported goods. Furthermore, with respect to the profit margin element of the importer’s transfer pricing formula, the margin is calculated based on a study of comparable and available data, of sales in the uncontrolled market to allow a reasonable profit to be earned. The margin is confirmed as often as required by the U.S. transfer pricing regulations, by a joint external study of the importer’s and exporter’s finance departments, also submitted by the importer for CBP’s consideration.
All comments relating to this pre-publication proposal should be sent to EarlyInputMailbox@dhs.gov no later than thirty days from the date of publication. Please put “Transfer Pricing” in the subject line. After analyzing the comments, CBP will consider whether to proceed further with this action in accordance with 19 U.S.C. §1625(c) by publishing a proposed revocation of HRL 547654.
Please note that statements provided in response to this request and the names of the submitters are not confidential and may be subject to disclosure upon a written Freedom of Information Act request.

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