| The Importance of International Transfer Pricing | Country Case: Argentina | | | | International Accounting – ACG6255 Professor Robert McGee Philip Archer | Table of Contents 1. Abstract 2. Transfer Pricing Overview 3. Defining Transfer Prices 4. Arm’s Length Principle 5. Pricing Methods 6.1. Comparable Uncontrolled Price Method (CUP) 6.2. Comparable Uncontrolled Transaction Method 6.3. Resale Price Method (RPM) 6.4. Cost-Plus Pricing Method (CPM) 6.5. Transactional Net Margin Method (TNMM) 6.6. Profit-Split Methods (PSM) 6.7. Advance Pricing Agreement (APA) 6. Argentina Overview 7. Transfer Pricing Rules in Argentina 8. Conclusion …show more content…
As Choi and Meek exemplify, transfers between related business units represent 60 percent of all international trades (Choi & Meek, p. 448). Thus, one can start to understand how important it is to define accurate transfer prices. As mentioned, the globalization of markets and the rapid development of communication systems have increased the presence of trades between companies under common control. However, other factors have also helped highlight the subject. Factors like the increase of service provided within MNE’s, the continuous trading activity and the use of financial instruments have increased the amount of trade between associated parties. Political forces have also assisted in the development of transfer pricing regulations, especially now during this economic crisis as governments try to increase their income through tax collection. For example, a parent company could pay less income tax in the US by determining a higher transfer price from the product it purchases from its subsidiary located in China. Since China’s corporate income tax is 25% and the US tax rate is 35%, this arrangement would generate a higher income at the subsidiary in China and less overall income tax payment for the financial group in question. Nevertheless, such arrangements can be prevented by tax authorities in the US, since according to Section 482 of the Internal Revenue Code “the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or
The week four individual paper addresses the implementation of Activity Based Costing (ABC) by Super Bakery, Inc., a virtual corporation founded by Franco Harris. Specifically, management strategies, the reasoning behind an ABC system, and the alternatives of a job order cost system or a process order cost system are assessed for this enterprise.
The "transfer pricing" provision attempts to identify the taxable income had the transaction been between unrelated parties dealing at arm's length.
Throughout years large American industrial companies have been running away from U.S. taxes, but there has been a new change. Companies such as Apple and Google have been affected by a change foreign countries are going through collecting higher taxes than before. It seems as if no longer can these companies get away with paying low taxes. This is happening because the European Commission have passed an order to collect high taxes. One example is Ireland who was ordered to collect fourteen billion dollars from Apple, which brought a surprise to this company. Companies have run out of places to run and pay one percent or less of taxes in foreign places, instead of paying back home.
However, the companies only have to pay the U.S. tax for foreign revenues once they bring the profits back to the United States. As a result of these current tax laws, U.S. companies that seek to avoid high corporate tax rates hold their foreign earned profits overseas. “It just makes no sense to pay a substantial tax on it,” said Joseph Kennedy, a senior fellow at the Information Technology and Innovation Foundation (Rubin, R.). It is far too easy for an IT corporation to create a patent in a foreign country and direct revenue to a corporation within that country, thus avoiding the much higher U.S. tax rates. According to Joint Committee on Taxation estimates, the lost revenue is increasing over time as corporations find even more creative ways to make their U.S. profits look like offshore income (Richards, K., & Craig, J.). As result, multinational American corporations have as much as $2 trillion held in overseas subsidiaries and if brought into the United States with the current tax laws, the federal government could benefit by nearly $50 billion per year.
MarketSoft founded by Greg Erman, in 1999 had designed an innovative software product that addressed the problem of managing sales leads across the “extended enterprise”. The product eLeads was strategically developed upon extensive research to address three critical areas many of the fortune 1000 companies in the modern times are facing: 1.Leads get lost 2. No qualifying systems for the leads exist and 3.The leads are never tracked.
Assignment 5: Based on your reading in Ch 9 in Kessler, the posted readings Morality Without Religion and Universality of Moral Law, the Socrates & St. Augustine power point, pgs. 24-39 in Nye, and the Popular Culture power point.
We are providing below the assumptions and other calculations we used while computing the WACC and the cash flows.
The main objective of many companies is to minimize their tax obligations. Jeffers (2014) discussed the reason of why companies adopt tax inversion strategies. The researcher indicated that the income maximization is a major reason of companies attempting to reduce their tax liability (pp. 100-101). Tax inversion strategies provide companies an advantage to lower income tax rate. Today, U.S. corporations renounce its U.S. citizenship and move to low-tax countries. Companies that reincorporate oversees are not obligated to pay U.S. taxes on earning income (p. 99). Many countries implement tax competition strategies to attract and retain businesses. Well-known companies, such as Exxon Mobil, Hewlett Packard, Tyco, General Electric, PepsiCo, etc. take benefits of tax shelter opportunities overseas (p. 102). Other benefits of the jurisdiction abroad are flexible banking laws and simplified litigation processes.
Write a 1200-1500 word paper that describes a strategic compensation plan for machine operators at Plastec Company. Refer to the description from the week 3 assignment. Include at least 3 referenced articles and cite them as appropriate. This paper should at a minimum address the following:
Opportunity cost is the value of the next best alternative in a decision. Imagine that you have $150 to see a concert. You can either see "Hot Stuff" or you can see "Good Times Band." Assume that you value Hot Stuff's concert at $225 and Good Times' concert at $150. Both concerts cost $150 per ticket, but it would take you a couple of hours to drive to Hot Stuff's concert and you have to be in school (the next) morning for an exam. Good Times' concert is right here in town. Explain how you would assess the opportunity cost of seeing Good Times in concert. What is the opportunity cost of going to Good Times' concert?
Intercompany transactions could occur across national borders, it would lead MNC companies to get more exposure to the differences of the tax regulations between countries. This might lead MNC companies to set up their objective to minimize their taxes through the use of discretionary transfer prices. These issues are attracted the attention of the member of the U.S. senate, foreign governments and international organization such as the OECD, G20 and European Union (EU).
There are several methods of setting transfer prices among profit centers within the same organization. Each profit center tries to set transfer prices which maximize their own profit. The buying and selling profit centers’ profits are largely affected by transfer prices. For example, when a high transfer price is charged, the selling division’s profits increase, while the buying division’s costs increase. So, transfer pricing should be established on a reasonable and objective basis, which should maximize the companywide profit, rather than being based on
Finally, in order to complete a more accurate comparison between the two projects, we utilized the EANPV as the deciding factor. Under current accepted financial practice, NPV is generally considered the most accurate method of predicting the performance of a potential project. The duration of the projects is different, one lasts four years and one lasts six years. To account for the variation in time frames for the projects and to further refine our selection we calculated the EANPV to compare performance on a yearly basis.
The price ceiling is the maximum price a seller is allowed to charge for a product or service. An impact on society includes when the prices are so high of a product, that no one can buy it. A price floor is the lowest legal price a product or service can be sold at. When market price is at its lowest, it may still be too high for consumers to purchase products. Governments can intervene for any purpose, and they are the ones who set these price controls.
Today’s highly competitive business world forces companies to create different tactics and relatively rely on multiple pricing strategies to conduct business.