Integrated Transfer Pricing and Customs Solutions

Integrated Transfer Pricing and Customs Value Solutions

The need to coordinate transfer pricing and trade and customs

Pricing Decisions Now Drive Both Tax and Tariffs

Transfer pricing and trade and customs have traditionally operated in parallel, with one focused on income tax and profitability and the other focused on import values and duty compliance. That separation no longer works.

While transfer pricing policies and adjustments may influence the values declared for related-party imports. Pricing decisions now carry simultaneous tax and duty consequences, making this a shared financial issue.

The Misalignment

Both functions evaluate related-party pricing, though they do so through different frameworks. Without coordination, this creates a structural disconnect. Prices set to achieve arm’s-length tax outcomes may also form the basis of customs values, but the two frameworks apply different rules and documentation requirements. Transfer pricing operates on periodic testing while customs authorities apply values transaction by transaction. Year-end adjustments may improve tax results but may increase duties and trigger additional obligations. As a result of these instances of misalignment, transfer pricing policy can be optimized for tax while still creating cost or risk for customs.

Tariffs Have Raised the Stakes

Tariffs have turned pricing into a margin-sensitive decision. A single adjustment can shift both sides of the equation, either improving tax outcomes while increasing duty costs or reducing tariffs while introducing transfer pricing risk. In many cases, tariff costs may offset or erode expected tax benefits. Decisions made in isolation can now create real financial leakage.

The Gap

Most companies have a transfer pricing framework in place but lack a coordinated approach across transfer pricing and customs. Intercompany prices are often set first, with customs implications assessed later. This reactive model leads to unexpected duty costs, inconsistent positions and increased audit exposure.

A Better Approach: Shared Framework

Leading organizations are moving to a coordinated model where transfer pricing and trade and customs are evaluated together before pricing decisions are implemented.

A Shared Framework Brings Clarity Across

Exposure: Where tariffs and margin are most impacted
Alignment: Whether transfer pricing policies support declared customs values
Adjustment impact: How true-ups affect duties
Total cost: Tax, tariffs and earnings before interest, taxes, depreciation and amortization (EBITDA) are viewed together.
Defensibility: Consistent, audit-ready support

How Kroll Can Help

Kroll’s Transfer Pricing and Trade and Customs practices operate as a single integrated service line.

Related-party valuation requires both disciplines—tax and customs—to work together, combining transfer pricing policy, intercompany profitability and tax documentation with customs valuation, import compliance, duty impact and audit readiness.

The result is a shared framework that manages tax, tariffs and financial performance together, before issues arise. When transfer pricing and trade and customs operate as a single framework, companies gain full cost visibility, reduce unexpected tariff exposure, strengthen their defensibility and better protect margins in a tariff-driven environment.

We help organizations move from a reactive to a coordinated stance by:

Identifying intercompany import flows with the greatest duty, tariff and EBITDA impact
Assessing whether transfer pricing policies support declared customs values
Unifying income tax optimization with tariff mitigation strategies
Evaluating the duty impact of year-end and retroactive transfer pricing adjustments
Quantifying income tax, tariff and margin effects together
Documentation Designed To Support Both Tax And Customs Positions.
Establishing practical coordination across tax, customs, finance and supply chain teams
Navigating differences in dispute resolution related to customs, transfer pricing and tax

Stay Ahead with Kroll

Transfer Pricing

Kroll's team of internationally recognized transfer pricing advisors provide the technical expertise and industry experience necessary to ensure understandable, implementable and supportable results.

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Trade and Customs

Kroll helps clients proactively develop strategies, manage risks, uncover and address compliance gaps, and respond to investigations or enforcement actions across the full spectrum of trade and customs challenges.