Criteria for the acceptability of the transaction value in imports with related parties

Abstract

This study seeks to identify, given the difficulties in interpreting and applying the Customs Valuation Agreement, which criteria are used to define whether the transaction value adopted in import operations between related parties is acceptable.  The deductive method will be used, and a critical legal analysis, bibliographical review of doctrine and study of judgments by the Administrative Council of Tax Appeals will be carried out. In the end, it will be concluded that there are two ways to guarantee the acceptability of the transaction value: preferably through approximation with test values; or through examination of sales circumstances, which is more subjective.