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Customs Valuation Review

A customs valuation review that follows every dollar paid to a related seller, from the ledger to the part of transaction value it belongs to, before CBP asks.

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See a related seller's year traced screen by screen ↓
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The problem

The invoices were right, and the money that matters never reached them

The trade team samples entries against invoices and finds nothing wrong, because the invoices are right. What is missing sits elsewhere: a year-end transfer pricing adjustment booked by tax months after the goods cleared, parts procurement bought and shipped free to the affiliate, a royalty paid to a licensor out of accounts payable.

None of it names an entry, and customs is rarely told. The tax study is filed for the tax return and offered to CBP as if it settled the related-party question. By the time an outside auditor connects the journal to the entries, most of them have liquidated, and a quick correction has turned into a prior disclosure or a protest.

Built forTrade compliance managersControllers and tax directorsCustoms counselLicensed customs brokers

The Problem Today

Tax books a year-end price adjustment to the affiliate, and no entry ever hears of it.

49.0%
of US imports in 2025 were between related parties, per Census published
21 mo.
to file a value reconciliation from the earliest flagged entry published

Kept apart from customs today

  • Ledger
  • Agreements
  • Parts buys
  • Tax study
  • Tax and customs kept apartThe transfer pricing study never meets an entry
  • Found once entries liquidateBy then only disclosure or protest remains

The Solution

  1. Each payment tracedLedger, entries and agreements read, each dollar drawn to a part of value
  2. Read as CBP wouldA challenger tests the map, the agents' own errors included
  3. Tax and the affiliate answerFields and files move the case; any note is held for a reader
  4. Open and liquidated apartOpen entries corrected; liquidated entries go to counsel

Built-in controls

  • Counsel signs anything said to CBP
  • A supplier note waits for a named reader
  • Whoever proposes cannot sign second

What You Get

The importer corrects what is still open and knows what the rest would cost before an audit asks.

  • Royalty questions put to counselLicense clauses read against the imported goods
  • Next year flagged at filingA blanket reconciliation flag reports the next adjustment
  • Past rulings become rulesA controller's ruling applied once counsel approves
Features

Customs valuation review features, from the general ledger to counsel's desk

Trade compliance, finance and counsel use them to find what never reached an invoice. The screens follow one year of purchases from an affiliate.

demoAll sample data: the affiliate and its buyer, the kit maker, the broker, each name, entry number and amount.

  1. 01Payments found

    Payments to and for a related seller found in the ledger and payables

    • General ledger and payables read for the seller. Payments to the affiliate and to third parties for its goods surface together, so an adjustment or a parts invoice under another vendor name is not missed.
    • Each payment with its source and confidence. The manager opens the invoice, journal or agreement behind a payment in one click before relying on it.
    • Agents named with their hand-offs. The agent list shows which agent is reading what and who it passes to, so a stalled step is visible while the run is live.
  2. 02Value map

    Each payment drawn to a part of transaction value under 19 U.S.C. 1401a

    • Price, packing, commissions, assists, royalties, proceeds. Each payment lands in one bucket of the statute or in not part of the value, with the deciding passage quoted beside the line.
    • Never declared, parked and out shown apart. Undeclared amounts, lines parked for counsel and lines that stay out of value are colored differently, so the open question is plain.
    • A royalty parked for counsel in plain words. The manager parks a line in plain words while counsel reads the license; it stays out of every total, and a line that adds value cannot be parked.
  3. 03Challenger

    The value map attacked first in an import specialist's own questions

    • Questions in the import specialist's own words. Each point names the rule it rests on and who must answer it, so the weak spots in the file show before anyone relies on it.
    • The agents' own drafting errors caught. A decrease after importation that the draft subtracted is moved out of value and labeled as the agents' error, so the addition is not understated when the manager proposes.
    • Legal questions handed to counsel by name. Whether a royalty is a condition of sale goes to counsel's desk with the license sections attached, and no agent offers an opinion.
  4. 04Requests sent

    Requests to tax and the affiliate that ask only what the file lacks

    • Fixed fields and files, never open questions. Each request asks only what the file cannot show, such as tax's true-up workpaper by product, so nobody is asked for a date the agreement already holds.
    • Replies change the case only through fields. A workpaper that does not cover every product, or a return without the adjusted price, sends the point to counsel instead.
    • Parked parties are not contacted. A request the manager parked stays unsent, so the licensor hears nothing while counsel is still reading the license.
  5. 05Related-party price

    Transfer pricing study set against the related-party customs value tests

    • Tax study beside circumstances of sale and test values. What the study proves for tax sits beside what customs still asks, so the study is not offered to CBP as an answer.
    • Five factors for a post-import adjustment. Each factor is marked shown, not yet or for counsel, beside its evidence, so the gaps in the adjustment's support are plain.
    • The affiliate's margins filled from its answer. Cost and margin before and after the adjustment arrive in fields from the affiliate's portal and fill the panel directly.
  6. 06Supplier note

    Assist from parts shipped free to the seller, held until a note is read

    • A supplier note shown word for word. No agent summarizes a supplier's note; the manager reads it and records what it changes, even nothing, before the assist line can move.
    • Assist valued at cost plus delivery, one per unit. Components bought by procurement and sent to the seller are counted per valve from the bill of materials, ready to declare.
    • Design work done in the United States kept out. Engineering drawn up at home is mapped out of the assist, so value is not overstated on the way to fixing an understatement.
  7. 07Duty what-if

    Added duty split between entries still open and entries already liquidated

    • Treatment, assist spreading, royalty and rate as inputs. The manager changes an assumption and sees what each treatment adds, without filing or deciding anything.
    • Open and liquidated entries counted apart. What can still take a post summary correction is separated from what has only disclosure or protest left.
    • The route for each group named. Open, liquidated, new and already-filed entries each show their next step, so the manager proposes a route per group rather than one answer for the year.
  8. 08Open entries

    Adjustment share and assist worked out entry by entry for corrections

    • Adjustment spread by entered value. Each open entry carries its share of the adjustment and its kits, so the broker's corrections tie to the map.
    • Protest window and liquidation shown per entry. Liquidated entries still inside the protest window are filtered in one click for counsel.
  9. 09Proposal

    Corrections, a reconciliation flag and counsel's referral in one proposal

    • Four actions in one proposal. Corrections for open entries, a blanket flag for new entries, the assist on new entries and the liquidated entries for counsel move together.
    • Blockers listed until the file is complete. An outside reply still due or a note still unread stops the proposal, so nothing is signed on a partial file.
    • Signing order set before anyone signs. The controller signs second, counsel signs the wording to CBP, and the broker's filing stays closed until counsel has signed.

Who owns a related-party customs value, from tax to the broker

Trade compliance proposes, finance confirms, counsel speaks to CBP and the broker transmits.

Trade compliance managers

Lead each related seller's yearly review, steer the agents, propose the treatment

  • Payments traced from the ledger, not invoices
  • Replies in fields, supplier notes word for word
  • Open and liquidated entries split before deciding
Controllers and tax directors

Own the transfer pricing study and sign the proposal as second person

  • The adjustment invoice and clause opened first
  • The tax study read against customs tests
  • Earlier rulings shown at the decision
Customs counsel

Sign the wording sent to CBP and choose the route for liquidated entries

  • Royalty and related-party questions with sources
  • Liquidated entries with added value and duty
  • A privileged log kept out of the exports
Licensed customs brokers

File post summary corrections and the blanket reconciliation application

  • Filing opened only once all have signed
  • Per-entry figures that tie to the map
  • What is missing named on the file button
More screens

The review queue, the affiliate's portal and counsel's desk for one year

Where the year's review starts, how the affiliate answers, and where it ends.

Before anything is readThe statute's parts of value on the right and seven agents waiting; the map says nothing until the agents have read.
The affiliate's portalThe affiliate's finance manager answers cost and margin in fields; any other payment is a yes or no with an amount.
Related sellers, tooling and licenses queuedThree related sellers by year, two tooling programs and two license agreements, each with owner, due date and status.
A ruling waiting to applyA controller's ruling on year-end adjustments is proposed as a rule; it applies only when counsel approves it.
The valuation file by yearEach document behind the year's value, where it came from, and the decisions still open, with privileged items listed as excluded.
Counsel's deskThe wording to CBP, the liquidated entries with their duty and protest window, and the parked royalty wait here for counsel.

demoSample data, from the working solution.

Four signatures before a corrected customs value reaches CBP

Each signer opens the record behind the signature first, and a proposer cannot be the second signer.

Trade compliance manager
Sees
The value map, the challenger's points, the outside answers and any unread note
Signs
The proposal: corrections, the reconciliation flag, the assist on new entries and the referral to counsel
Controller and tax director
Sees
The adjustment invoice and the agreement clause behind it, opened before the button works
Signs
As second person on the proposal, or sends it back with a reason code
Customs counsel
Sees
The full correction wording and the liquidated entries with their duty
Signs
The wording sent to CBP, and a privileged route for liquidated entries that a second person confirms
Licensed customs broker
Sees
Which signatures are still missing, named on the filing button
Signs
Nothing new: transmits the corrections and the blanket application exactly as signed

Seven agents map the money; legal questions go to counsel

Each reads one kind of record; its output goes to another agent or to a named person.

Ledger reader

Finds payments to the seller and for its goods in accounts payable and the general ledger.

  • Writes nothing to the ERP
Entry reader

Reads entry summaries for value, lines, liquidation and reconciliation flags.

  • Files nothing
Agreement reader

Reads agreements, licenses, kit invoices and bills of materials, and quotes the passage.

  • Never opens counsel's privileged area
Value mapper

Draws each payment to a part of transaction value with its passage and confidence.

  • Decides no condition-of-sale or related-party question
Valuation specialist

Plays the CBP import specialist against the map and raises points, including any decrease after importation.

  • Never says anyone acted on purpose
  • Gives no legal view
Records agent

Sends structured requests to tax, the affiliate and suppliers, and reads the fields and files that come back.

  • Never treats a supplier note as evidence
  • Contacts no party a person parked
Duty calculator

Works out added value and duty per entry, open and liquidated, under each treatment.

  • Recommends no route

What importers ask about customs valuation with related sellers

What is a customs valuation review?

A customs valuation review checks that the declared value of imports includes every payment the law counts in transaction value, such as assists, royalties paid as a condition of sale and transfer pricing adjustments. Here agents trace each payment to a related seller into transaction value, and people sign each correction.

Is a year-end transfer pricing adjustment part of the customs value?

A payment to the seller for the goods is part of the price actually paid or payable, and CBP expects changes in a transfer price to be reported. The review draws the adjustment to price, spreads it over the entries and tests the factors CBP looks for, with counsel deciding what the file cannot.

Are parts shipped free to the seller an assist?

Materials and components the buyer supplies free and that are built into what is imported count as assists under the statute. The review finds them in procurement's invoices, values them at cost plus delivery and counts them per unit from the bill of materials. Design work done in the United States stays out.

Does the software decide whether a royalty is dutiable?

No. Whether a royalty is a condition of the sale is a legal question for counsel. The agents quote the license sections and show what including it would add, and the manager can park the line until counsel decides.

What happens to entries that have already liquidated?

They are counted apart, with their added value, duty and whether the protest window is still open. Counsel receives them with the full map, and counsel records a privileged route that a second person confirms. The agents recommend no route.

Who files the corrections with CBP?

The licensed customs broker, as post summary corrections for open entries and a blanket reconciliation application for new ones, only after the manager, the controller and counsel have signed.

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Trace one affiliate's year
you already filed.

Bring a year of entries from one related seller with its ledger and agreements, and we will trace its payments with you.

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