There is an overlap between the transfer pricing concepts that apply under tax and under customs regimes. This thesis aims to demonstrate (i) that customs and tax laws often share common principles in respect of related-party transactions; (ii) that transfer pricing as agreed to under one discipline should be recognized under the other; (iii) that the OECD Transfer Pricing Guidelines constitute a body of rules that is appropriate to supplement the related party provisions of the GATT/WTO Valuation Code ("GVC"); and (iv) that such guidelines are generally in accordance with the provisions of the GVC and its general principles and objectives. This thesis also analyzes the tax and customs value of imported goods, and identifies which additions to or deductions from customs value might have to be taken into account in comparing tax and customs results. The thesis concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing compensatory adjustments to transaction value would be consistent with Article 1 of the GVC.
| Identifer | oai:union.ndltd.org:LACETR/oai:collectionscanada.gc.ca:QMM.31165 |
| Date | January 2000 |
| Creators | Jovanovich, Juan Martʹin. |
| Contributors | De Mestral, Armand L. C. (advisor) |
| Publisher | McGill University |
| Source Sets | Library and Archives Canada ETDs Repository / Centre d'archives des thèses électroniques de Bibliothèque et Archives Canada |
| Language | English |
| Detected Language | English |
| Type | Electronic Thesis or Dissertation |
| Format | application/pdf |
| Coverage | Master of Laws (Institute of Comparative Law.) |
| Rights | All items in eScholarship@McGill are protected by copyright with all rights reserved unless otherwise indicated. |
| Relation | alephsysno: 001783375, proquestno: MQ70345, Theses scanned by UMI/ProQuest. |
Page generated in 0.0017 seconds