Settlements between related entities and the impact of the customs policy introduced by the new US administration.
Implementation of customs policy and its impact on global trade
We are currently witnessing a change in the trade and customs policy of the world’s largest economy, the United States. Changes in customs tariffs may have long-term effects on the functioning of international companies.
The rise of protectionism and the use of tariffs as an effective tool for economic pressure will undoubtedly influence companies’ transfer pricing strategies.
Transfer pricing and the impact of the new customs policy
Transfer pricing should be understood as a mechanism for settling transactions between related entities, in particular within a single capital group, often operating in different jurisdictions.
The issue of customs policy in 2025, including the introduction of customs duties on certain goods, will significantly affect the business strategies of companies and the transfer pricing policies of global companies.
For example, a change in customs duty rates on finished products or imported components (e.g. in the technology sector – duties imposed on semiconductors or in the automotive industry on imported parts) forces companies to adjust their transfer pricing strategies and pricing policies in order to reduce their tax burden and maintain and preserve their competitiveness.
Companies can respond to these changes by, among other things:
- Modifying supply chains – changing suppliers or adjusting margins between related entities;
- Amending contracts (including prices at headquarters and distributors);
- Adjusting transfer pricing policies – changing pricing structures within the capital group to reduce the impact of customs duties and minimise the negative impact of higher customs rates, as well as changing margin policies and the comparative method used;
- Adjustment of transfer pricing models to optimise tax and customs burdens while maintaining compliance with international tax regulations;
- Analysis of new potential risks and review of existing benchmarking analyses for their relevance;
- Relocation of production – moving operations to countries with lower customs duties;
- Re-analysis of the profitability of transactions.
Undoubtedly, interference in customs duties will affect the profitability of related entities. The imposition of new duties by the US government may significantly change the transaction models and pricing policies of companies operating on international markets. In order to remain competitive and optimise costs, it is essential to thoroughly understand these changes and their potential effects.
It should be remembered that measures related to potential transfer pricing adjustments (adjusting transfer prices resulting from imposed customs tariffs to market conditions) will also be subject to assessment by Polish tax authorities in terms of compliance with market criteria (arm’s length principle).
In summary, the European economy faces new challenges, and businesses must consider revising their existing transfer pricing policies and methods.
The changes taking place may force entrepreneurs to update their optimal transfer pricing policy or create a new transfer pricing model.
Transfer pricing 2025: support from Moore Polska Tax & Legal
Ensure compliance and optimisation of transfer pricing in 2025!
Moore Polska Tax & Legal supports its clients every day in all aspects of transfer pricing.
Customs changes can significantly affect your business. We offer professional advice on transfer pricing and pricing strategies, helping you minimise your tax burden and adapt your policies to new regulations. Contact us to secure your competitiveness!
If you have any questions about the 2025 transfer pricing changes or other issues, please do not hesitate to contact us.
