Chapter 12: International Transfer Pricing Flashcards Preview

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Flashcards in Chapter 12: International Transfer Pricing Deck (10):
1

Transfer Pricing Definition

Determination of the price at which transactions between related parties will be carried out

Related parties/Intercompany transactions: subsidiary to parent (upstream), parents to subsidiary to parent (downstream)

2

Types of Intercompany Transactions and Their Associated Price

Sales of tangible property - Sales Price
Use of tangible property - Rental or Lease Payment
Use of intangible property - Royalty, licensing fee
Intercompany loans - Interest rate

3

Two Factors Influence Which Transfer Price is Determined

First factor: management control and performance evaluation, and minimization of cost

Second factor: laws in countries governing the manner intercompany transactions may be priced

4

Transfer Pricing Method

1. Cost-based transfer price
2. Market-based transfer price
3. Negotiated price

5

Cost-based transfer price

Based on actual or budgeted variable and fixed production costs. Includes profit margin for the seller

Problems: which measure of cost to use and inefficiencies in one unit may be transferred to other units.

6

Market-based transfer price

Transfer price is based on price would have been charged to unrelated parties or determined by reference to sales of similar products

7

Negotiated Price

Negotiation between buyer and seller

Needs to have external market for the items being transferred. Disadvantage: time-consuming and the agreed price shows the manager's negotiation ability instead of ability to control costs and generate profit

8

Decentralization Advantages and Disadvanges

_Allowing local managers to respond quickly to changes
_Dividing large, complex problems into managerial pieces
_Motivating local managers

Disadvantage: managers make decision for self-interest

9

Goal Congruence

Accounting and control system should be designed to provide incentives for local managers to make decisions that consistent with corporate goals

10

Objectives of International Transfer Pricing

1) Performance Evaluation:
. Buyers (goods sold) and seller (more revenue)
. Control subsidiary of the parent
2) Cost Minimization:
. Minimize income tax by recording profits in lower-tax countries
. Avoidance of withholding taxes
. Minimization of import duties (tariffs)
. Circumvent profit repatriation restrictions
. Protect cash flows from currency devaluation
. Improve competitive position of foreign operation
+Conflicting objectives: