The recent CJEU ruling on Hamamatsu Photonics Germany may increase the administrative and compliance burden for related-party trade into the EU. Interpretations of the ruling by tax advisers indicate that transfer pricing valuation methods may no longer be applicable when determining customs values.
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Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
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