US hardware manufacturer imported finished goods into China at a transfer pricing that left China with a small profit. When the Chinese customs authority challenged the per unit pricing reported claiming it should be higher, CRA’s transfer pricing group provided both external per unit pricing support as well as the economic reality of increasing pricing leaving the China entity at a loss and its impact on corporate taxation overall.
Who bore the tariff burden? Economics of IEEPA refund disputes
The refund question sits at the intersection of customs procedure, administrative law, but also economics, and resolution will likely vary significantly across...