Low-Hanging Fruit? Kenyan Pineapple Case Sheds Light on Functional Characterization and the Use of Customs Valuation Methods for Transfer Pricing
New
Journal
Country
International; Kenya
Published Date
Issue
International Transfer Pricing Journal 2026 (Volume 33), No. 4
Document
This article examines the Kenyan Del Monte case to explore how export oriented countries may classify the functional and risk profile of harvesting entities. It showcases how customs methods are used for transfer pricing purposes within a tax audit.