... Complex organizational structures help achieve business objectives such as increased profitability and reduced risks. Also, these complex structures allow the company to reduce its overall tax burden. One such strategy is discussed in this paper. Transfer pricing allows the company to price the inter-company transactions. Transfer pricing simplifies the accounting of transactions that take place between affiliated or related entities. Companies have freedom in valuing inter-company transactions. But, if strategically implemented, this strategy allows the company to save taxes and retain large amount of profits. Keywords: Transfer mispricing, tax-havens, Double Irish Dutch Arrangement Transfer Pricing Transfer pricing is the methodology used to set the prices for goods sold or services provided between related entities within an enterprise. Related entities are those which are under control of a single corporation and include branches and companies that are wholly or majority owned ultimately by the parent company. Generally, such a transfer price should be equal to the price which the entity would charge to an independent customer, an arm’s length customer. Such a price is termed as an “arm’s length price” (Transfer Pricing, Wikipedia, 2015). Financial accounting does not differentiate between affiliates and treats the corporate group as a single entity. But the federal income tax law treats affiliates as separate economic actors. This allows multinational companies a...
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...GLOBAL TRANSFER PRICING SERVICES Global Transfer Pricing Review kpmg.com TAX © 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. All rights reserved. Contents Introduction Country Snapshots Country Overviews Glossary of Terms Find out more 2 4 10 255 256 © 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. All rights reserved. 2 | Global Transfer Pricing Review Introduction © 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. All rights reserved. Introduction | 3 As multinational companies continue to globalize their supply chains, transfer pricing is increasingly at the forefront of business transformation initiatives. Organizations recognize that transfer pricing strategies can add significant value to business projects and help fund future growth as they look to maximize efficiencies and minimize their global tax liabilities. The transfer pricing environment is constantly changing, in terms of both risks and opportunities. Multinational companies...
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...length price. * The CUP method is the most direct way of ascertaining an arm’s length price. It involves the direct price comparison for the transaction of a similar product between independent parties. * Comparability Analysis * An uncontrolled transaction is comparable to a controlled transaction for purposes of the CUP method if one of the following conditions is met: * None of the differences (if any) between the transactions being compared or between the enterprises undertaking those transactions could materially affect the price in the open market; or * Reasonably accurate adjustments can be made to eliminate the material effects of such differences. * An MNE using the CUP method to determine its transfer price must first identify all the differences between its product and that of the independent manufacturer. The MNE must then determine whether these differences have a material effect on the price, and adjust the price of products sold by the independent manufacturer to reflect these differences, to arrive at an arm’s length price. A comparability analysis under the CUP method should consider amongst others the following: * Product characteristics such as physical features and quality. * If the product is in the form of services, the nature and extent of such services provided. * Whether the goods sold are compared at the same points in the production chain. * Product differentiation in the form of patented features...
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...CASE STUDY Chapter SIX CASE 6-1 Case Study on “Transfer Pricing Problems” Case SUMMARY Division A of Lambda Company manufactures product X, which is sold to Division B as a component of product Y. Product Y is sold to Division C, which uses it as a component of Product Z. Product Z is also sold to customers outside of the Company. The intracompany pricing rule is that product are transferred between divisions as standard cost plus 10 percent return on inventories and fixed assets. Case Questions Question a: with transfer price calculated in Problem 1, is Division C better advised to maintain its price at $28 or follow competition in each of the instances above? Answer: Under possible competitive price $27.00 If company maintain the price at $28, the profit=(28-23.6) ×9,000=39,600 If company follow the possible competitive price at $27, the profit= (27-23.6) ×10,000=34,000 Under possible competitive price $26.00 If company maintain the price at $28, the profit=(28-23.6) ×7,000=30,800 If company follow the possible competitive price at $26, the profit= (26-23.6) ×10,000=24,000 Under possible competitive price $25.00 If company maintain the price at $28, the profit=(28-23.6) ×5,000=22,000 If company follow the possible competitive price at $25, the profit= (25-23.6) ×10,000=14,000 Under possible competitive...
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...Merloni Group Introduction: Merloni Group (1930) is a diversified, multinational appliance manufacturer headquartered at Fabriano in Italy. Its technical and production oriented strategy with outstanding growth and diversification record helped it to become fourth largest manufacturer in Italy in 1970’s. Due to death of its founder Aristide Merloni in 1970 and success of product diversification in 1950’s and 1960’s, they changed their organizational structure from functional to product division. But due to economy slow down in Europe and resulted oil crisis, appliance market has experienced slow demand growth which led to focus on international markets by domestic players. To fill the capacity and lower their costs, Merloni expanded into other markets with subsidiaries in 6 European Nations. Ariston France is one of the sales subsidiary selling low and medium priced appliances of parent line in France. In spite of increased sales from high prioritised market France, AF experienced huge losses which lead to conflict between Headquarters and subsidiary due to difference in opinion of Organizational structure and Strategic mission linking parent and subsidiary company. International Strategy of Merloni: The international strategy of Merloni's appliance division was to sell all of its product line in each national market through its subsidiaries. Due to slow growth rate and oil crisis in Europe, it began expanding its operations in other markets from 1970. Due to high competitive...
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...Transfer Pricing Kim: “I ... don’t understand why it would make sense to pay $450/ton for pulp [to buy internally from Northwestern’s U.S. pulp mills] when I can get it for $330/ton from Chile.” Ewing: “I understand your motivation for wanting to source the pulp from Chile, but it is important [to buy inside] for the corporation to act as an integrated team.” Barrett and Slape (2000: 597) Executive summary The quote above is an excerpt from a phone conversation between Bill Ewing, the Vice President of Northwestern Paper Company 1, and Arthur Kim, the Director of Northwestern’s South Korean subsidiary. This conversation rises questions on the advantages and disadvantages of utilizing internal transfer prices. Such as: given that some subsidiaries are located in lower tax jurisdictions, would it not be logical to set lower internal transfer prices to those subsidiaries? Would it not be logical to allow the Korean subsidiary to purchase from outside suppliers given that internal transfer prices are much higher than market prices in Chile? Allowing subsidiaries to outsource externally would lead to the bankruptcy of the US subsidiaries, which would not have enough demand for their products? What are the advantages and disadvantages of a reward system based on the allocation of internal consumption? Is the allocation process “fair” to each subsidiary? Is it “fair” to the company as a whole? Questions and doubts on transfer pricing probably haunt not only Mr. Ewing and the Northwestern...
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...The introduction of a line of standardized and non-customizable S001 & S00 3 elevators. 2.) The local supply of materials and companies. It had been 8 months since Napoli took up office and there hasn't been a single sale. Things had gone wrong. The strategic implementation of the business plan was not as easy as anticipated and the lack of infrastructure and support from the European plants is causing the implementation the much harder. HOW SHOULD HE DEAL WITH THE CHALLENGES HE IS FACING OVER TRANSFER PRICES AND LIMITED TECHNICAL COOPERATION FROM THE EUROPEAN PLANTS? The transfer pricing and the lack of technical cooperation from the European plants are crippling the organization. Both of these problems need Napoli's immediate attention. The businesses plan main objective was to develop a unique competitive advantage by outsourcing manufacturing to local companies. This would allow Schindler India to avoid the excessively high import duties and transfer pricing while keeping overhead costs extremely low. It is my opinion that...
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...ACCG330: Strategic Management Accounting LECTURE 12 CONTROL PROBLEMS AND PRACTICES IN MULTINATIONAL ORGANISATIONS ACCG330 Readings: Anthony & Govindarajan (2007, pp.678-696) ACCG330 Strategic Management Accounting Session 1, 2012 Learning Objectives 1. Describe management control problems and practices in multinational corporations. 2. Explain problems and issues associated with global organisations: i. Cultural differences and their impact on management controls. ii. Transfer pricing and related issues in multinational corporations. iii. Effects of exchange rates on multinational corporations and control system design issues. ACCG330 Strategic Management Accounting Session 1, 2012 1 Nature of Multinational Corporations (MNCs) • What is a Multinational Corporation? – A corporation that owns and operates production facilities in two or more countries. OR – A corporation with power to coordinate and control operations in two or more countries without owning them. • Typically have Headquarters in the country of origin • Build or acquire affiliates or subsidiaries in other countries (the host nation) ACCG330 Strategic Management Accounting Session 1, 2012 Basic Structures of MNCs • A number of basic structures exist that permit an MNC to operate and compete internationally – Structure must meet the need of both the local market and the home-office strategy of globalization – Basic structures of MNCs: • Domestic structure plus foreign subsidiary...
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...Caribbean Brewers: Transfer Pricing, Ethics and Governance Abstract Caribbean Brewers is a fictitious company although the case depicts a real international business situation focusing on transfer pricing, ethics and governance. It exposes students to the role of management accounting concepts such as cost allocation and transfer pricing in terms of how they impact the performance and reward of individuals at different levels within the organization. Students are also exposed to impact of the management accounting and control tools/methods used upon stakeholder interests. The case puts the new comptroller in a difficult position with respect to discharging his or her professional and ethical responsibilities when the interests of the different stakeholders are at odds with one another (e.g., majority and minority shareholders, individual managers and tax authorities). It contains a good balance of quantitative and qualitative analyses, and forces students to delve into the issues in some depth. The ethical issue forces students to think hard about how they would react when facing similar situations. The case offers considerable flexibility to the instructor to emphasize different aspects contained within depending upon the specific course and the level at which it is being used; it can also work well as an integrative case. The case is most suitable for use in advanced undergraduate management accounting courses as well as graduate level courses including those in...
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...Macalester, Inc., manufactures heating and air conditioning units in its six divisions. One division, the Components Division, produces electronic components that can be used by the other five. All the components produced by this division can be sold to outside customers; however, from the beginning, about 70 percent of its output has been used internally. The current policy requires that all internal transfers of components be transferred at full cost. Recently, Loren Ferguson, the new chief executive officer of Macalester, decided to investigate the transfer pricing policy. He was concerned that the current method of pricing internal transfers might force decisions by divisional managers that would be suboptimal for the firm. As part of his inquiry, he gathered some information concerning Part 4CM, used by the Small AC Division in its production of a window air conditioner, Model 7AC. The Small AC Division sells 100,000 units of Model 7AC each year at a unit price of $55. Given current market conditions, this is the maximum price that the division can charge for Model 7AC. The cost of manufacturing the air conditioner is computed as follows: Part 4CM …………………… $ 7 Direct materials …………….. 20 Direct labor ………………… 16 Variable overhead ………….. 3 Fixed overhead ……………… 6 Total unit cost ………………. $52 The window unit is produced efficiently, and no further reduction in manufacturing costs is possible. The manager of the Components Division indicated that she could...
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...Generally speaking, cost-based transfer pricing is top management chooses a transfer price based on the costs of producing the intermediate product. For instance, variable production costs, variable and fixed production costs, full costs (including life-cycling costs) as well as some markup. It is useful when market prices are unavailable or too costly to obtain. When a large organisation transfers product across international borders, transfer prices are relevant in the calculation of income taxes, and are sometimes relevant in connection with other international trade and regulatory issues (Horngren, Datar, Foster, Rajan, Lttner, 2009). When transfer prices are based on full cost plus a markup, it may probaly lead to sub-optimal decisions. Since it causes the buying division to regard the fixed costs and the markup of the selling division as a variable cost. Indeed, the buying division may then purchase products from an external supplier expecting savings in costs that will not exist (Horngren, et al, 2009). In a large company, the transfer price is a major factor between manufacturing and distribution divisions. In order to achieve company profit maximization when decentralized segments of a company interact, a transfer pricing system should be established that treats supplying segments as variable cost recovery centers and setup costs are treated as a variable function of run size. This induces optimal run sizing decisions by the producing and purchasing divisions. ...
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...20 An important order in 2002 (Develop Type 2A engine) Quantity = 5000 engines Variable cost per unit = 2500 Full cost per unit = 4000 Development cost = 200 Profit = 750 (if sells engines externally) Problem No. 1 What transfer price should Kamp insist on, in your opinion, if it were to supply the type 2a engine to the MB division now and in the future? Please give arguments for your proposal. You should at least consider the principle ‘minimum transfer price = variable cost per unit + opportunity costs for the supplier’ and the guidelines Vecu has for transfer prices. Please draw attention to the interests of Kamp Motors as well as those of Vecu as a whole. Taking into consideration Vecu’s transfer price policy, what do you think of Guy Mercier’s attitude? Given: Quantity = 5000 engines (for Type 2A) Full Cost per unit = €4000 (for Type 2A engine if calculated in usual way) Development Cost = €200 (For developing the Type 2A engine) Variable Cost per unit = €2500 Opportunity cost = €750 (Profit if sell engines externally) Calculation: Minimum Transfer Price = Variable cost per unit + Opportunity costs = €2500 + €750 = €3250 + 200 (Development Cost) Proposed Transfer Price = €3450 - Now...
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...ACCOUNTING H525: MANAGERIAL ACCOUNTING AND CONTROL Winter Quarter 2004 INSTRUCTOR: Professor D. L. Jensen 428 Fisher Hall jensen.7@osu.edu (I check my e-mail several times daily and will respond ASAP) 292-2529 at office (Please leave recorded message; if I'm not in, I'll return your call.) 488-8177 at home (Please leave recorded message; if I'm not in, I'll return your call.) Office Hours: By appointment or chance COMMUNICATIONS CONSULTANT: Ms. Rama Ramamurthy 640 Fisher Hall ramamurthy.3@osu.edu 292-7397 Office Hours: REQUIRED TEXT MATERIALS: Anthony and Govindarajan. Management Control Systems, Eleventh edition. Homewood: Irwin, Inc., 2004 (abbreviated A&G) Supplementary materials (abbreviated S) are sold in a package by CopEz. Some supplementary items may be distributed in class or made available on the Internet. OPTIONAL MATERIALS FOR REFERENCE: Horngren, Charles T., George Foster, and Srikant M. Datar. Cost Accounting: A Managerial Emphasis. Eleventh edition. Upper Saddle River, NJ: Prentice-Hall, 2003 (or another cost accounting text) Kaplan, Robert S., and Robin Cooper. Cost and Effect: Using Integrated Cost Systems to Drive Profitability and Performance. Cambridge, MA: Harvard Business School Press, 1998. Kaplan, Robert S., and David P. Norton. The Balanced Scorecard: Translating Strategy into Action. Cambridge, MA: Harvard Business School Press, 1996. ...
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...CHAPTER 23: TRANSFER PRICING Chapter Contents: - Definition and Overview - Transfer Pricing Options - Market-based Transfer Prices - Cost-based Transfer Prices - Negotiated Transfer Prices - Survey of Practice - External Reporting - Dual Transfer Pricing - Transfer Pricing and Multinational Income Taxes - Other Regulatory Issues Definition and Overview: A transfer price is what one part of a company charges another part of the same company for goods or services. In the excerpt from Casablanca, Rick apparently loaned Ferrari 100 cartons of cigarettes for which he was never repaid. Now that Ferrari owns both the Blue Parrot and Rick’s Café, he jokes about the fact that what was previously a debt that he owed to Rick, is now a “debt” from one nightclub that he owns to another nightclub that he owns. If Ferrari continues to transfer cartons of cigarettes between the two clubs, he might wish to establish a “transfer price” for cigarettes, but knowing Ferrari, he won’t bother. We will restrict attention to transfers that involve a tangible product, and we will refer to the two corporate entities engaged in the transfer as divisions. Hence, the transfer price is the price that the “selling” division charges the “buying” division for the product. Because objects that float usually flow downstream, the selling division is called the upstream division and the buying division is called the downstream division...
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...Abrams Company Abrams Company’s top management had three areas of concerns regarding the management control in its company. a).The first concern was the disputes over the transfer pricing between three part-divisions and After Market division, especially for parts that exclusively sold to AM division. To reduce the dispute Abram’s top management to establish a fixed price for the exclusive parts, the fixed should cover the COGS and other expenses attributable to parts manufacturing plus divisional appropriate profit. The transfer price will be determined by adjusting the fixed price to resemble the price change caused by inflation. The fixed price determination must be established in conformity with all part divisions, AM division, and corporate level as the ultimate controller of company’s overall performance. b) Product division too often treated the AM division as a captive customer. The second focus of concern of the Abrams‘ top management was the behavior of part divisions, which captivated the AM division. Again, this is the consequence of Abrams Company organizational structure; the treat of divisions as profit centers, according to theory, will abdicate some control of top management since some decision makings authority are delegated to the lower level. This is the case in Abrams Company, where its division losing it synergy to reach companywide common goal. To overcome this problem Abrams Company needs to change its reward system, and plant managers will have...
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