“Trade discounts” and “customs value”. An issue awaiting final resolution

I. By way of conceptual introduction

The composition of the calculation base for the “transaction value” in import operations of the Mercosur countries is established – substantially – based on two legal bodies, namely: on the one hand, at the multilateral level, the Agreement on Implementation of Article VII of the General Agreement on Tariffs and Trade 1994 (GATT)” (hereinafter, “WTO Valuation Code” or “Agreement”), and on the other hand, at the regional level, the Decision of the Common Market Council of Mercosur No. 13/07.

These provisions establish the different “methods” by which the “customs value” is determined, and consequently, when a “value adjustment” is required, and under what conditions it must be carried out. However, the aforementioned body of regulations does not expressly address one of the most important commercial modalities in international trade, namely, the granting of “discounts” by suppliers to their foreign importers.

In this article, we will attempt, in a very superficial way, to examine the concept of “discount”, its characteristics and requirements to be accepted as such, by the “Agreement”, that is, to prevent the aforementioned “discount” from having to be subject to a “positive adjustment” or a further questioning, in the area of ​​infringement.

II. “Trade discounts”: Should the customs value be included when setting the basis for calculating the taxes paid on the import? 

In general, the conduct to be followed by the Customs Administration of WTO Members in determining the customs value of goods, with respect to “trade discounts” or price reductions, depends essentially on their nature, that is, as demonstrated by the study of the factual elements involved in the transaction. Broadly speaking, it can be stated that any “discount” that meets the condition of "generality", and that, therefore, be freely granted to all buyers in the importing country who are on equal footing, should not be included in the “customs value”, but – on the contrary – beforehandDiscounts that are of a very "special" nature or that are "abnormally low" could not be excluded from the aforementioned "transaction value". In such cases, the Customs Authority shall have the right to consider that there is a “reasonable doubt” regarding the accuracy or truthfulness of the “customs value”, and to put the corresponding “declaration of value” under investigation (1).

Similarly, it must be considered that the "discount" or price reduction should reflect the economic or commercial reality of the item for which it is granted, and that a particular name should not be used to conceal another commercial situation: for example, declaring a "quantity discount" to Customs when, in reality, what is being granted is a "sales agent commission." Thus, considering these two conditions: "generality" y “reality” (2) – as will be seen later – “discounts” or price reductions can be classified as follows: “admissible” (or non-incremental), and “not admissible” (and therefore incremental).

III. See in full, on this aspect: (Stiglio, E. 2018)

Okay, we'll proceed in foreground, to carry out a brief review of the conceptual background of the topic raised; and, in second termWe will detail the current regulations on this matter, both at the multilateral and regional levels. 

The issue under consideration focuses on two topics related to the customs valuationnamely: in Firstwhich happens when the foreign supplier grants “discounts” to the national importer, that is, whether or not they should be included in the calculation base declared at the time of importation; and in second placeIf the first answer is affirmative, which of these are "admissible" for these purposes (and which are not), and what requirements must be met to tolerate this circumstance. Of course, if the answer is negative, the "value adjustment" of the precept must be made.

With regard to the first question raised, and without prejudice to what will be explained below, it can be stated that, according to multilateral and regional regulations, different commercial and customs circumstances may be considered, such that there will be “discounts” which in some cases will result “admissible”and others who, on the contrary, will clearly be “not admissible”Therefore, without prejudice to the general conclusions we attempt to reach, we must bear in mind that there will be many situations in which the analysis of the specific case will be the only way to determine its legal and customs viability, and consequently, whether the corresponding "discount" should be included in the "price paid or payable." In this regard, our analysis will focus on examining what “discounts” which are “permitted” and which are not, in light of current customs regulations, and; in the first case, that formal requirements These must be taken into account for their authorization by the Customs Authority.

IV. Continued

The “Preamble to the “Agreement” sets out several “principles” that serve as a guide for the application and interpretation of the “valuation methods” (3) And among them – the fundamental “principle” – is that The basis for customs valuation of goods should be, to the greatest extent possible, their "transaction value". (4)

Thus, the “general principle” derived from the “Agreement” is to accept the decisions of sellers and buyers in order to form their prices, considering them as the basis of the “customs value”(5)

This acceptance signifies the abandonment of the “principle” according to which two shipments of the same merchandise, arriving from the same place, at the same point of entry, at the same time and in the same quantity, must have the same “customs value”(6)

According to the procedure based on the “transaction value”, each shipment must be valued according to its own price, even if this differs from that of another identical shipment (7).

This “principle” applies, whatever the reason for the price difference, even if an importer obtains a lower price, for example, as a result of some kind of "discount"as will be seen below, with the exceptions stipulated in the "Agreement" itself (8).

In this sense, the attempt to conceive of the “customs value” as a “theoretical or ideal value” that should occur between independent buyers and sellers in a system of absolute free competition is rejected.  

Therefore, in the new rating system, which currently governs international trade relations for WTO Members, who together represent more than 98% of world trade (9) “Market values” are no longer used, and prices will be the “real” prices of each transaction. (10) (11).

V. What about the specific issue of “discounts”?

🟦a. The concept of “discount”

Bearing in mind that the “price of a product”, is nothing other than the consideration fixed by mutual agreement between the seller and buyer, and which must be paid by the latter, for the benefit of the former for the purposes of a sales contract, we will have to determine the concept of "discount".

Given its consensual nature, the "price" will be subject to change by agreement between the parties, either increasing or decreasing it. Therefore, a "discount" at the agreed price, will imply a modification that will reduce the original amount of said “price”. 

Thus, with its renewed presence, the "discount" It can then be defined as that reduction, freely agreed between the parties, to the price of merchandise for various reasons that will be of interest to the contracting parties, and which may respond to factors such as advertising promotions, international fairs, early payment, quantity purchased, seasonality, etc.

🟦b. Treatment of “discounts” in the “Agreement”

However, it can be argued that it is entirely logical that the “Agreement” did not include any express stipulations regarding “trade discounts”because the payment of a discounted price is nothing other than the payment of the "price actually paid or payable" referred to in the regulations on customs valuationIndeed, by constituting the "discount" a deduction on the “gross price” (“price” without "discount"), the result of this subtraction (“gross price” minus "discount") is the “net price”, that is, the “price” that the buyer is obligated to pay, and therefore, it is nothing other than the “price actually paid or payable”, to which we have referred and which the “Agreement” expressly mentions as the primary basis for calculating the taxes paid on the occasion of importation. Based on this, we can conclude that, after the application of a “trade discount”which will be relevant in terms of customs valuation (according to the “transaction value method”, first valuation “method” (12) , will be the accreditation of payment of the “net price” (“price” to which the "discount" granted by the foreign provider).

In determining the “transaction value,” the “Agreement” does not consider the “price” in question as a “price structure model” or as a “market price,” and therefore, it is irrelevant how the parties arrived at the contractual determination of said “price.” In this sense, the “price” is simply accepted—and, eventually, “adjusted” in accordance with Article 8 of the “Agreement.” – or is excluded, due to any of the circumstances provided for the rejection of the corresponding “transaction value” (13)

Therefore, in principle, it makes no difference whether the "discount" The respective price is offered or not to other buyers (in the same or a different market than that of the importer in question), or if the "price" quoted to the predicted importer does not entail the "discount" which is offered to others. Similarly, the "discount" or price reduction, must be adjusted to the "economic-commercial reality" of the concept for which it is granted, and cannot imply a maneuver tending to hide another commercial situation, for example that a “quantity discount”when in reality, what is being granted is a "sales agent commission".

And that's because, the “Discount” cannot be remuneration for other goods, services, or rights that the seller obtains from the buyer, but must be part of the same transaction. 

Therefore, it doesn't matter the reason why it was granted "discount" corresponding (adaptation to market prices, incentive for future sales expansion, etc.), the The only limitation is that it does not indirectly constitute payment for other goods, services, or rights obtained from that buyer. (14).

We will now look at some types of “discounts” that have been specifically analyzed by World Customs Organization Technical Valuation Committeeand what have been the pronouncements, limits, requirements and “validations” issued in this regard.

2.1. “Allowable discounts”

There are a series of “discounts” very common in international trade that are considered as “admissible” in light of current regulations.

Among them, the following can be mentioned, namely:

a) “Discounts for cash payment”

These “discounts” They are the counterpart to the “interests”, which obviously constitute financing of the price. 

In those cases, the seller grants a price reduction for the cash payment – ​​this, of course, is not financed – made by the buyer.

In this regard, the Technical Committee for Customs Valuation that operates in the field of World Customs Organization (WCO), spoke in the Advisory Opinions (OC) 5.1; 5.2 and 5.3. 

In OC 5.1The situation arose that, when valuing imported goods, the buyer may have already benefited from the "discount" respective. And in this case, the Technical Committee He recalled, among other things, the following: “…since, according to Article 1 of the Valuation Agreement, the transaction value is the price actually paid or payable for the imported goods, the cash discount must be accepted when determining the transaction value.”.

For its part, in the OC 5.2. The same criterion was maintained. This ruling addresses the case in which a buyer may benefit from a “discount for cash payment” offered by the seller, but unlike the previous circumstance, the payment had not yet been made at the time of the respective valuation. 

And finally, the Technical Committee concludes that the fact that payment has not yet been made in no way implies that the provisions of Article 1.1.b) are applicable and that “…therefore, there is nothing preventing the use of the sale price to establish the transaction value under the Agreement”.

Likewise, in the OC 5.3.It was stated that “…when the buyer can benefit from a discount for cash payment, but at the time of valuation the payment has not yet been made, the amount that the importer has to pay for the goods will be accepted as the basis for the transaction value according to Article 1.”. 

Finally, the aforementioned OC 5.3. It touches on a significant issue, namely those cases where the price has not yet been paid, and the importer tries to prove to the Customs Administration that the price will indeed be paid (with the "discount" (duly granted), in the future. 

And in that regard, the Technical Committee has established in said OC that “…the testing methods may be different”, and in that sense, “…a statement on the invoice itself could be accepted as sufficient proof, or a declaration by the importer regarding the amount to be paid could serve as the basis for the decision, without prejudice to verification and the possible application of Articles 13 and 17 of the Agreement”.

If a "discount" higher to “generally usual”The same may be accepted by the Customs Administration, provided that the buyer has benefited from a similar discount in most of the same transactions during the last year (16).

b) “Quantity discounts”(17)

Regarding the treatment that should be applied to the “quantity discounts” pursuant to Article 1 of the “Agreement”, the Technical Committee for Customs Valuation has expressly stated – among other things – that:

• • • The “quantity discounts” These are price reductions on goods that the seller grants to customers based on the quantities purchased during a certain period.
    • The “Agreement” makes no reference to a standard amount to be taken into account when deciding whether the “price actually paid or payable” for the imported goods constitutes a valid basis for determining the “customs value” under Article 1.
    • Therefore, the following will be taken into account for the respective valuation: “the quantity on which the unit price of the goods being valued has been set, when these were sold for export to the country of import.”
    • Thus, “quantity discounts” They occur only when it is demonstrated that a seller determines the price of their merchandise according to a fixed scheme based on the quantity of goods sold.

c) “Discounts based on sales level”

It often happens – due to a number of commercial factors – that importers who operate at the wholesale or distributor level obtain better prices from their foreign suppliers than those actually available to retail merchants.

When this occurs, the “net price” they pay for the imported goods will be accepted as the “transaction value” as long as it meets the requirements established by Article 1 of the “Agreement”.

Thus, neither the aforementioned Article 1 of the “Agreement”, nor its Interpretive Note They make no reference to the commercial level at which the importers operate, but Articles 2 and 3 of the "Agreement" do, establishing "valuation methods" based on "transaction values ​​of goods identical or similar to those imported."  

And in that sense, both provide that – to apply them – sales made at the same commercial level as the imported goods must be taken into account, and in turn, when there are only precedents of goods sold at another level, an “adjustment” must be made based on that difference in level.  

The commercial reality expressly recognized in those texts is implicitly admitted in Article 1, since the "price actually paid or payable" may well be the one resulting from making effective a "discount" granted according to the importer's level. (18).

2.2. “Inadmissible” discounts

However, there are other series of “discounts” that – although, within the framework of a commercial operation, they may be granted by the seller to the buyer – they must be duly added to the corresponding “transaction value”, and their deduction from the respective calculation base is not admissible.

Among them, the following can be mentioned:

a) Indirect payments and/or “retroactive discounts”

According to Agreement, both the “indirect payments” as “retroactive discounts” They form part of the "price actually paid to be paid" for the respective merchandise, and therefore, they must be "added" to it.

In this regard, it is worth remembering what is meant by “indirect payments”, to the amounts that form part of the commercial value of the goods but do not appear on the invoice, for example, the cancellation by the importer, in whole or in part, of a debt owed by the supplier; whereas the “retroactive discounts”, such as those “discounts” granted in relation to previous commercial transactions, for example, “discounts” granted to correct mistakes in previous shipments. 

So, in the OC 8.1 el WCO Technical Committee argued that the amount of the “discount” granted based on previous transactions, “It represents an amount that has already been paid to the seller, and is therefore covered by the Interpretative Note to Article 1 concerning the “price actually paid or payable”, which specifies that the price actually paid or payable is the total payment made or to be made by the buyer to the seller. Therefore, the discount forms part of the price paid and, for valuation purposes, must be included in the transaction value.”.

b) Discounts that disguise a “price advance”

Similarly, Customs Administrations have traditionally rejected the assumptions “discounts” since they intended to conceal the cancellation of a debt owed by the seller to the respective buyer, as – it has been understood by them – that said “discount” in the price actually corresponds to a “indirect payment”and as such, it should be included in the "price actually paid or payable".

c) Other “non-deductible” and therefore “inadmissible” discounts

As previously stated, the “discounts for cash payment” to “quantity discounts”These, among others, are acceptable under the “Agreement”. Advisory Opinions 5.1 to 5.3 and 15.1 of the WCO Technical Assessment Committee, refer to the treatment applicable to such “discounts”.  

However, it is possible that they will be granted “discounts” for the following reasons – in addition to those already listed – in which case they may not be "deductible":

• • • The buyer undertakes certain activities for or on behalf of the seller, as part of the payment, in accordance with the sales contract;
    • the buyer provides other goods or services to a third party, on behalf of the seller, as a condition of sale of the imported goods; 
    • The relationship between the parties effectively influences the corresponding price.

🟦c) Acceptability requirements for “discounts” granted by the supplier to the importer

We will now see what the requirements are. “discounts” or discounts granted by the seller of the imported goods must meet certain requirements in order to be considered as “admissible” in light of current multilateral and regional regulations.

Therefore, if these conditions or requirements are met, they will be accepted—in principle—for determining the “customs value,” since the actual and total payments from the buyer to the seller will constitute—in such cases—the basis of the “transaction value method.” Therefore, the “price actually paid or payable” obtained after applying these conditions or requirements will be the basis for determining the “customs value,” since the actual and total payments from the buyer to the seller will constitute—in such cases—the basis of the “transaction value method.” “discounts” or discounts, must be accepted by the Customs Administration, provided that:

• • • El "discount" is related to the goods being valued;
    • El "discount" has been stipulated before the shipment of the goods, as part of the negotiation agreed between the seller and the buyer;
    • It's not a “retroactive discount”, granted for goods imported prior to the one to which the reduction is being applied or "discount", corresponding to transactions independent of that of the merchandise being valued;
    • The buyer is actually benefiting from "discount"That is, that the conditions that gave rise to it are met; and
    • In the commercial invoice and/or sales contract, with a certain date prior to the shipment of the goods, the price of the goods must be distinguished and the concept and amount of the discount or discount must be identified. "discount" respective (19) (20) (21) (22) (23)

🟦d) General conclusions

Neither Article 1 of the “Agreement” nor its Interpretive Note They contain provisions relating to the “discounts” of price, which the seller of the imported goods may be able to grant.

imported goods. However – as Professor Daniel Zolezzi reminds us –  “It is essential to the positive notion of value that imported goods be valued at the price actually paid for them. That is to say, if the seller grants discounts in consideration of certain commercial terms, there is nothing preventing the resulting price from being accepted as the transaction value.” (24)

Indeed, it is also worth remembering that the "Preamble" of the "Agreement" specifically states that: “The basis for customs valuation of goods should be, to the greatest extent possible, their transaction value”. 

As we can see, the message is clear in that the Customs Authority must exhaust all possibilities to determine the “customs value” based on the aforementioned “transaction value”.

In other words, for the “Agreement” – in this respect and in any other related respect – customs valuation – What is really important is the accreditation of the “price actually paid or payable”, which is nothing other than the accreditation of the reality underlying the operation that originates the import.

Therefore, in order for the "discount" granted by the supplier of the respective goods, be "admissible" In accordance with current national and international regulations, it must meet two conditions, namely: on the one handto possess the aforementioned characteristics to be effectively accepted as such; and on the other hand, be expressly stated in the respective commercial invoice that is presented for dispatch, and/or formalized in a transaction contract duly signed between supplier and importer, with a certain date and prior to the corresponding dispatch.

In case the "discount" If the aforementioned meets both conditions, it must necessarily be accepted by the Customs Administration, and even if it questions it, which is not expected to happen, it will surely receive judicial validation within the Judicial Branch.

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Notes and References

1. See in particular: Article 17 of the “Agreement” and Decision 6.1 of Customs Valuation Committee.

2. See in full, on this aspect: (Stiglio, E. 2018).

3. (Sherman, S & Glashoff, H., 1988, p. 61).

4. Professor Daniel Zolezzi argues that this is a key assertion to understand the privilege given to the positive notion of value, which is then incorporated into the operative part of the "Agreement" in Article 1 (Zolezzi, D. 1987, pp. 1 et seq.).

5. (González Bianchi, P. 2003, pp. 89/90).

6. Labandera, P. Tax Magazine.

7.(Labandera, P., 2021, pp.430/442).

8.(Herrera Ydañez, R. & Goizueta Sánchez, J. 1985, pp. 85/86).

9.https://www.wto.org/spanish/thewto_s/whatis_s/inbrief_s/inbr_s.htm#:~:text=MIEMBROS:%20166%20miembros%20que%20representan%20el%2098%25%20del%20comercio%20mundial.&text=FUNCIONES (viewed on 21/03/2026).

10. (Zolezzi, D. Argentine magazine “El Derecho”, 1993, p. eleven).

11. (Lucas, G. & Labandera, P., Tax Magazine, 2008, pp. 47/62).

12. Articles 1 and 8 of the “Agreement”.

13. In this regard, it should be noted that in relation to this aspect, it can be verified that: either a structural rejection, in accordance with the provisions of Article 1.1 of the “Agreement”, if the regulatory requirements of the “method” are not met; or, a rejection “due to reasonable doubt”, in accordance with the provisions of Article 17 of the “Agreement” and Decision 6.1 of Customs Valuation Committee.

14. (Lascano, JC 2003, pp. 93 et ​​seq.).

15. It should be remembered that at the Mercosur level, if there is an express provision that contemplates – in relation to the customs valuation – the potential granting of financing, and the treatment that should be given to “interest” in these cases. For this purpose, we refer to the relevant regulation: Article 8 of Decision No. 13/07 of the Mercosur CMC

16. (Herrera Idañez, R. & Goizueta Sánchez, J., 1985, pp. 103/104). 

17. See in this regard: Advisory Opinion 15.1.

18. (Zolezzi, D. 2003, p. 81).

19. Regarding this point, prestigious Uruguayan legal scholars do not share the aforementioned assertion. In this regard, see (González Bianchi, P., 2003, pp. 88 et seq.). The position currently held by the Uruguayan Customs Administration and part of our jurisprudence, in the few cases in which it has been called upon to rule on the matter, is that the required approach to the formalization of the “discounts” In the customs field, the situation is different and consistent with the aforementioned requirement. Thus, by way of example, it is worth recalling what was stated in this regard by... Court of Appeals in Civil Matters, 5th Shift, which in judgment No. 125/2010 of September 15, 2010 – unpublished – has maintained:  “…Nor had he declared the discounts he later invoked, which were unknown to the customs broker and did not appear on the invoice; and which, even if applied, do not eliminate the differences with the actual value of the merchandise. It cannot be accepted that it is common practice for the discount not to appear on the invoice in any way. All aspects of a purchase transaction can be reliably documented by the buyer, if he so desires; and all must be reflected in a manner that ensures a correct and complete declaration.”.

20. In a similar vein, important foreign doctrine has stated:  “…it is important to note that for the verification of a declared price, the price actually paid or payable may also be the result of applying a rebate or discount granted by the seller; for example, for quantity, for cash payment, to compensate for deficiencies in previous deliveries, etc.” The author adds that “such discounts may be accepted by the customs authority for the valuation of goods and should not be subject to adjustment, provided they are related to the goods being valued, genuinely benefit the buyer, are granted to any buyer under the same conditions, are distinguished from the price of the goods on the commercial invoice, and are not a retroactive discount.” (empty Regarding this: SANCHÉZ, JI General Secretariat of the Andean Community, 2007, p. eleven).

21. In a similar vein, important foreign doctrine has stated:  “…it is important to note that for the verification of a declared price, the price actually paid or payable may also be the result of applying a rebate or discount granted by the seller; for example, for quantity, for cash payment, to compensate for deficiencies in previous deliveries, etc.” The author adds that “such discounts may be accepted by the customs authority for the valuation of goods and should not be subject to adjustment, provided they are related to the goods being valued, genuinely benefit the buyer, are granted to any buyer under the same conditions, are distinguished from the price of the goods on the commercial invoice, and are not a retroactive discount.” (empty Regarding this: SANCHÉZ, JI General Secretariat of the Andean Community, 2007, p. eleven).

22. This is reaffirmed by Resolution 1884 of 2014 of the Andean CommunityOn Customs Valuation, that in his article 10, 1., numeral iv e ultimately prayer:  

"1. Discounts or rebates granted by the seller of imported goods will be accepted for determining customs value, since the actual and total payments from the buyer to the seller form the basis of the Transaction Value Method. The price actually paid or payable, obtained after applying such discounts or rebates, will be accepted provided that:

(...)

1. 1. In the commercial invoice and/or sales contract, the discount is distinguished from the price of the merchandise and the concept and amount of the discount is identified.

(...)

If any of these conditions are not met, the discounts granted by the seller will be disregarded by the Customs Administration for the purpose of determining the customs value of the imported goods. In such cases, these discounts must be considered as part of the price paid or payable for calculating the customs value.   It can be seen in: http://www.aduana.gob.ec/contents/nov/news_letters_view.jsp?anio=2014&codigo=229 (Last viewed: 20/3/2026).

23. It is also worth recalling what was stated in a recent ruling issued in 2014 by the Court of Justice of the Andean Community which – among other considerations – expressed the following:

“…THIRD: The Customs Administrations of the Member Countries of the Andean Community have the right to carry out the necessary controls and investigations, for the purposes to ensure that the customs values ​​declared as the taxable base are correct and determined in accordance with the conditions and requirements of the WTO Valuation Agreement.   

FOURTH: As the WTO indicates, customs valuation must be based, with notable exceptions, on the actual price of the goods being valued, which is generally indicated on the invoice. This is understood to be the primary method used by the authorities. Customs valuation based on the transaction value method depends largely on the documents submitted by the importer.   

FIFTH: In the present case, the price actually paid or payable obtained after applying such discounts or rebates will be accepted provided that: “the commercial invoice and/or sales contract distinguishes it from the price of the goods and identifies the nature and amount of the rebate.” In other words, the discounts or rebates must be distinguished from the price of the goods, and the nature and amount of the rebate must be identified, whether in the commercial invoice or the sales contract. It is sufficient to prove this with either of these documents.” (see the aforementioned judgment in: http://www.tribunalandino.org.ec/web/index.php?option=com_wrapper&view=wrapper&Itemid=67) (Last viewed: 20/3/2026).

24. Along the same lines, one can also see the response from the Customs of the Argentine Republic to the proposal duly made for this purpose by the Customs Clearance Center of that country (empty in: http://www.cda.org.ar/index.php?option=com_content&view=article&id=4986:gestiones-del-centro-declaracion-de-valor-en-aduana&catid=67&Itemid=89) (Last viewed: 20/3/2026). 

25. (Zolezzi, D. 2003, p. 79). 

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