Sergo Dreving 
Coexistence of Customs Valuation Transaction Value Method and Transfer Pricing Transactional Net Margin Method in Multinational Enterprises Importing Goods from Switzerland to Germany [PDF ebook] 

Master’s Thesis from the year 2024 in the subject Law – Tax / Fiscal Law, grade: 1.3, University of Münster (Faculty of Law), language: English, abstract: The master’s thesis explores the complex relationship between Transfer Pricing (TP) and Customs Valuation (CV) in multinational enterprises (MNEs), focusing on the compatibility of the Transactional Net Margin Method (TNMM) and the Transaction Value (TV) method.
Using a legal framework analysis, the study examines regulatory overlaps and conflicts, particularly in the context of tangible goods imported from Switzerland to Germany.
The research highlights the impact of retrospective TP adjustments on customs values and assesses whether a harmonised approach to TP and CV is legally and practically feasible.
The findings suggest that, despite their distinct objectives, both disciplines can be reconciled through proactive compliance strategies, integrated documentation, and regulatory engagement.
The thesis provides practical recommendations for MNEs, offering a structured framework to navigate these dual regulatory environments while considering administrative practices and relevant case law.