Prezzi di trasferimento e valore in dogana (per operazioni tra parti correlate): valutazioni parallele in cerca di convergenza.

In international trade, there is a well-known divergence between the valuation of goods for income tax purposes (transfer pricing) and the valuation of goods for customs purposes (customs value), in the case of transactions between related parties. This valuation divergence leads to complications for traders and, from an international trade perspective, it may seem a logical contradiction that the same goods can be assigned different tax values. Applying a strictly legal analysis, however, such valuation divergences are not unjustified, since the logic underlying the two separate tax fields is structurally different. Nevertheless, efforts by tax and customs authorities to minimise valuation di- vergences and achieve an acceptable alignment in the valuation of the same goods are to be welcomed. It is increasingly the case, in international practice, that customs authorities are recognising transfer pricing documentation drawn up by multinational groups, considering such documentation to assist in the de- termination of customs value in transactions between related parties. However, there are good reasons to acknowledge that the determination of the customs value of goods can affect valuations for income tax purposes (transfer pricing).