関税局―評価事前教示回答―ロイヤルティー関係 ５月８日
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CTB Valuation Office publishes advance ruling on royalty payment
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CTB shares the ruling considering royalty payment for multiple royalty factors, i.e. brand managements, marketing, sales in importing country as well as the good to be imported.
I would like to lead the readers’ attention to the very last sentence of the Valuation office’s reasoning.
I think this reason is not the appropriate interpretation and application of WTO valuation agreement Article 8 and its note.
Valuation Office ruling
http://www.customs.go.jp/zeikan/seido/kanzeihyouka/H30jirei/jizen_koukai_30_8.pdf
WTO Valuation Agreement
https://www.wto.org/english/docs_e/legal_e/20-val_01_e.htm
