Answer first
Core rule
Answer first: relationship alone does not disqualify transaction value. The price may be accepted when the circumstances of sale show that the relationship did not influence it, or when the price closely approximates an eligible test value at or about the same time, with appropriate commercial-level, quantity, additions, and seller-cost adjustments. The October 2026 exam uses the 2025 Annual CFR; current-law valuation work requires a separate current-source check.
Authority and lookup route
Locate the rule before returning to the facts. Links point to government or official publications.
Reference lookup task
Build a two-column table for circumstances of sale and test values, including the evidence and adjustments required by each route.
Route: Read §152.103(j)(2) first, then §152.103(l)(1)–(2) for examples and closely-approximates factors.
Worked example
A parent seller prices goods to its U.S. subsidiary using the same formula used for unrelated distributors. The price recovers all costs plus a profit representative of the seller's same-class sales.
- 1Identify the parties as related, but do not reject transaction value automatically.
- 2Choose the circumstances-of-sale route rather than assuming a test value exists.
- 3Compare the pricing method, cost recovery, and profit evidence with §152.103(l).
- 4Treat the evidence as support for acceptance, subject to CBP's evaluation of the full record.
Conclusion: The facts can support a finding that the relationship did not influence the price, but they do not compel automatic acceptance without CBP review.
Common traps
- Rejecting every related-party transaction value automatically.
- Treating a tax transfer-pricing study as conclusive customs evidence.
- Using an unsupported, noncontemporaneous, or unadjusted comparison as a test value.