Simply Trade

Transfer Pricing, Customs Valuation & Tariffs: Bridging the Gap with Alex Martin


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Episode: Simply Trade #413

Hosts: Andy Shiles & Lalo Solorzano
Guest(s):

  • Alex Martin, Transfer Pricing Specialist, KBKG

    Published: December 18, 2025
    Length: ~37 minutes
    Presented by: Global Training Center

    Episode Summary

    Tariffs have changed everything — and many companies are still missing the second-order effects.

    In this episode, Andy and Lalo sit down with Alex Martin of KBKG to unpack one of the most misunderstood (and increasingly risky) intersections in global trade: transfer pricing and customs valuation.

    As tariffs rise from single digits to 25%, 50%, and beyond, decisions once made solely by tax or finance teams now carry massive customs consequences. Alex explains how multinational companies are getting “whipsawed” between Customs and the IRS — one pushing values up for duty, the other pushing values down for income tax.

    This conversation makes one thing crystal clear: customs, tax, finance, and compliance can no longer operate in silos.

    Whether you’re an importer, trade compliance professional, CFO, or tax leader, this episode highlights why cross-functional coordination is now essential — not optional.

    Key Takeaways
    • Transfer pricing impacts both customs duties and income tax — often in conflicting ways

    • Rising tariffs have turned valuation into a material financial risk, not an academic exercise

    • Customs looks at transactions line-by-line, while tax authorities focus on annual results

    • CFOs and tax directors must now actively engage with trade compliance teams

    • Poor coordination can increase audit risk, cash-flow pressure, and margin erosion

    • Programs like FTZs, bonded warehouses, drawback, and cost bifurcation can help mitigate exposure

    • Asking for transfer pricing documentation is a powerful first step for trade teams

      Who Needs to Be at the Table?

      This episode stresses the importance of assembling a multi-disciplinary team, including:

      • Trade Compliance

      • Tax & Transfer Pricing

      • Finance / CFO leadership

      • Accounting (AP / AR)

      • Pricing & Sourcing

      • International affiliates and parent companies

        If tariffs have changed your margins, they’ve already changed your tax picture — whether you’ve addressed it or not.

         

        🔍 Transfer Pricing Insights from Alex Martin (KBKG)
        • Strategic transfer pricing adjustments can reduce customs duties by lowering inventory values and separating non-dutiable management fees

        • Many companies overlook the income tax benefits of transfer pricing, especially when foreign entities are profitable while U.S. operations show losses

        • Transfer pricing changes can significantly lower a company’s global effective tax rate when aligned correctly

        • KBKG regularly hosts transfer pricing education sessions to help trade professionals understand intercompany pricing from a tax perspective

        • KBKG also supports companies with R&D tax credits, cost segregation, and green energy incentives, alongside transfer pricing services

          Learn more:

          • Article: Higher Tariffs Are on the Way

            https://www.kbkg.com/feature/higher-tariffs-are-on-the-way

          • Free Webinar (CPA Academy): Transfer Pricing & Tariff Savings Strategies

            https://www.cpaacademy.org/s/webinar/a0DQh00000ZyzPXMAZ/transfer-pricing-and-tariff-savings-strategies

          • Article: Higher Tariffs Are on the Way

            https://www.kbkg.com/feature/higher-tariffs-are-on-the-way

          • Free Webinar (CPA Academy): Transfer Pricing & Tariff Savings Strategies

            https://www.cpaacademy.org/s/webinar/a0DQh00000ZyzPXMAZ/transfer-pricing-and-tariff-savings-strategies

             

            📚 Resources & Mentions
            • KBKG – Transfer Pricing & Tax Advisory

              https://www.kbkg.com/

            • Alex Martin – LinkedIn

            • Alex Marting YouTube videos
            • U.S. Customs Valuation Methods (WTO / CBP)

              https://www.cbp.gov/trade/valuation

            • IRS Transfer Pricing Overview (Section 482)

              https://www.irs.gov/businesses/international-businesses/transfer-pricing

            • Global Training Center – Customs Valuation E-Learning Course

              https://www.globaltrainingcenter.com/

            • Foreign Trade Zones (U.S. FTZ Board)

              https://www.trade.gov/foreign-trade-zones

              📢 Subscribe & Follow

              Stay connected with the Simply Trade community:

              • LinkedIn – Global Training Center

                https://www.linkedin.com/company/global-training-center?utm_source=SimplyTradePodcast

              • YouTube – Simply Trade Podcast

                https://www.youtube.com/@SimplyTradePod?utm_source=SimplyTradePodcast

              • Spotify – Simply Trade

                https://open.spotify.com/show/09m199JO6fuNumbcrHTkGq?utm_source=SimplyTradePodcast

              • Apple Podcasts – Simply Trade

                https://podcasts.apple.com/us/podcast/simply-trade/id1640329690?utm_source=SimplyTradePodcast

              • Trade Geeks Community

                https://globaltrainingcenter.com/portal/?utm_source=SimplyTradePodcast

                 

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