https://resources.comp-press.com/tags/transfer-pricing-and-tax/Recent content in Transfer Pricing and Tax on CompPress | Transfer Pricing ResourcesHugoen-usTue, 14 Apr 2026 00:00:00 +0000https://resources.comp-press.com/articles/transfer-pricing-customs-coordination/Tue, 14 Apr 2026 00:00:00 +0000https://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>https://resources.comp-press.com/articles/transfer-pricing-international-tax-architecture/Thu, 11 Dec 2025 00:00:00 +0000https://resources.comp-press.com/articles/transfer-pricing-international-tax-architecture/<p>Transfer pricing is one of several mechanisms in the international tax system for allocating multinational income across jurisdictions. It is the most analytically detailed of these mechanisms, but it is not the only one, and a transfer pricing position cannot be designed without reference to the others. This article surveys the broader architecture in which transfer pricing operates, identifies the principal interactions between transfer pricing and other international tax provisions, and illustrates one such interaction through a worked example. The discussion is global in framing, with US-specific provisions and OECD-aligned international rules treated together where each is most relevant.</p>