1. Rules to be harmonized
2. Is it necessary or at least advisable to harmonize both tax and customs transfer pricing regimes?
3. Is harmonization feasible?
4. Definition – OECD Guidelines
5. Recognition of the arm's length principle in the GVC
6. The OECD Guidelines can be used to determine whether transaction price is arm's length under GVC Article 1.2
7. Guidance for applying the arm's length principle. Use of such guidance under GVC Article 1.2
8. The OECD arm's length methods and the methods laid down in GVC Articles 2, 3, 5 and 6
9. Test values
10. Considerations regarding the OECD arm's length methods
11. Traditional methods
12. Other methods
13. Customs Value and Tax Value of Imported Goods. Adjustments
15. IRC Section 1059A
16. Definition of the term "related parties"
17. Tax base of customs duties
19. Price review clauses; formula pricing