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

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-t...

Free Webinar (CPA Academy): Transfer Pricing & Tariff Savings Strategies
https://www.cpaacademy.org/s/webinar/...

Article: Higher Tariffs Are on the Way
https://www.kbkg.com/feature/higher-t...

Free Webinar (CPA Academy): Transfer Pricing & Tariff Savings Strategies
https://www.cpaacademy.org/s/webinar/...




📚 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/intern...

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-z...

📢 Subscribe & Follow

Stay connected with the Simply Trade community:

LinkedIn – Global Training Center
https://www.linkedin.com/company/glob...

YouTube – Simply Trade Podcast
   / @simplytradepod  

Spotify – Simply Trade
https://open.spotify.com/show/09m199J...

Apple Podcasts – Simply Trade
https://podcasts.apple.com/us/podcast...

Trade Geeks Community
https://globaltrainingcenter.com/port...