https://resources.comp-press.com/tags/first-sale/ Recent content in First Sale on CompPress | Transfer Pricing Resources Hugo en-us Tue, 14 Apr 2026 00:00:00 +0000 https://resources.comp-press.com/articles/transfer-pricing-customs-coordination/ Tue, 14 Apr 2026 00:00:00 +0000 https://resources.comp-press.com/articles/transfer-pricing-customs-coordination/ <p>A single intercompany cross-border sale of goods is subject to two separate tax regimes. Income tax authorities apply transfer pricing rules to determine whether the price reflects an arm&rsquo;s length result. Customs authorities apply customs valuation rules to determine the dutiable value of the imported goods. The two regimes share an underlying interest in market-based pricing, but they are administered by different authorities, follow different valuation hierarchies, and create incentives that often pull in opposite directions. This article addresses the coordination of transfer pricing and customs valuation in the context of cross-border related-party transactions, with particular attention to the current US tariff environment as of early 2026 and to the First Sale for Export rule that remains a significant point of intersection between the two regimes. The discussion is US-led, with brief reference to OECD-aligned international practice where relevant.</p>