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현 광주본부세관장攀攀The primary basis for customs value of imported goods under WTO Customs Valuation Agreement is transaction value as defined in Article 1 thereof. In exceptional cases that there are restrictions as to the disposition or use of the goods by the buyer, the transaction value shall not be acceptable for customs purposes. Considering that, by the nature of TOLL manufacturing, disposition of medicine made from TOLL manufacturing is restricted to a specific person, the transaction value might be deemed as unacceptable by Customs authority. This study is to examine all aspects that the transaction value of material medicine for TOLL manufacturing might not be accepted as customs value, and to find that provisions rendering the transaction value unacceptable in the Agreement shall not be unduly stretched to alternative valuation methods and additionally Customs authority should make efforts to stick to the transaction value method by including the balance amount reduced by restrictions as to the disposition, other conditions or considerations in the customs value.