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Question: XYZ Corporation, a Canadian company, provided consulting services to its sister company ABC Inc., located in a different country. The total fees charged for the services were $150,000. However, a comparable arm's length transaction for similar services in the open market would have been $120,000. Calculate the transfer pricing adjustment for XYZ Corporation.
Answer: Transfer pricing rules require that transactions between related entities be priced as if they were unrelated parties dealing at arm's length. In this case, the actual fees charged by XYZ Corporation for consulting services to ABC Inc. are $150,000, while the arm's length price for comparable services is $120,000.
The transfer pricing adjustment can be calculated as follows:
Transfer Pricing Adjustment
=
Arm’s Length Price
−
Actual Price
Transfer Pricing Adjustment=Arm’s Length Price−Actual Price
\text{Transfer Pricing Adjustment} = $120,000 - $150,000 = -$30,000
The negative value indicates that the fees charged by XYZ Corporation are higher than the arm's length price. This adjustment of -$30,000 would be made to align the transaction with an arm's length arrangement. Tax authorities may adjust the taxable income of XYZ Corporation by reducing it by $30,000, considering the arm's length price for the services provided.
It's essential for companies engaged in transactions with related parties to adhere to transfer pricing regulations to ensure that prices are in line with those that would be charged between unrelated parties in an open market.
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from an external supplier. On the
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(South, Overall) = (decrease, no
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