이전가격의 관세평가와 관세범죄 기소에서 WTO 관세평가협정 적용에 관한 연구: 태국-필리핀 WTO 담배분쟁을 중심으로

The WTO Thailand-Philippines Cigarettes Dispute, which will be central to this study, is an example of in-depth discussion over each clause of the WTO Customs Valuation Agreement, as well as through the WTO Dispute Settlement Procedure, the Panel and Appeals Organization and the Implementation Conformity Procedure under Section 21.5 of the DSU. In addition, the need and implications of the research are significant in that the WTO panel judgment on the detailed provisions of the CVA on the transfer price, which have not been dealt with much, and the issue of how the CVA can be applied in the possible criminal prosecution of customs criminals within member countries, were discussed in depth. Therefore, this study drew up the issues that were mainly addressed in Thailand-Philippines Cigarettes Dispute Case and looked up the analysis and evaluation and implications of the issues. With the advanced transfer pricing in the multinational-led trade environment, tariff assessments on it will become more important, and not only tariff assessments, but also the manipulation of transfer prices could lead to cutoms crimes that greatly exceed the level of tax avoidance. In the future, it is time for Member States to conduct further research on practical discussions and methods that actively consider that the assessment of tariffs on transfer prices should not only be considered from a tax perspective, but that crimes originating from transfer prices may be substantially within the scope of the Convention on duty Assessment.