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AbstractTransfer pricing refers to the pricing of an intermediate product or service within a firm. This product or service is transferred between two divisions of the firm. Thus, transfer pricing is closely related to the allocation of profits in a supply chain. Motivated by the significant impact of transfer pricing methods for tax purposes on operational decisions and the corresponding profits of a supply chain, in this article, we study a decentralized supply chain of a multinational firm consisting of two divisions: a manufacturing division and a retail division. These two divisions are located in different countries under demand uncertainty. The retail division orders an intermediate product from the upstream manufacturing division and sets the retail price under random customer demand. The manufacturing division accepts or rejects the retail division's order. We specifically consider two commonly used transfer pricing methods for tax purposes: the cost‐plus method and the resale‐price method. We compare the supply chain profits under these two methods. Based on the newsvendor framework, our analysis shows that the cost‐plus method tends to allocate a higher percentage of profit to the retail division, whereas the resale‐price method tends to achieve a higher firm‐wide profit. However, as the variability of demand increases, our numerical study suggests that the firm‐wide and divisional profits tend to be higher under the cost‐plus method than they are under the resale‐price method. © 2013 Wiley Periodicals, Inc. Naval Research Logistics, 2013

This article studies one of the most complicated and yet popular company management tools, the transfer pricing. The author considers the aims and purpose of transfer pricing, the formation of a transfer pricing system as a company management tool, popular viewpoints on transfer price calculation methodologies, strengths and weaknesses of the existing approaches, and offers a hypothesis on transforming transfer pricing methods. The paper systematizes transfer pricing methods with due regard to the experience of domestic and foreign companies, the development of the Russian Federation legislation, the recommendations of the OECD, and the studies of auditing and consulting companies. The author presents an overview of the most popular transfer pricing methods which serve as a basis for using one or another method, identifies the factors of efficient management mechanism. The article analyses the specific features of using a particular management mechanism in financial companies and companies operating in real economy, studies the methodology to deploy transfer pricing in a legal entity and within a vertically integrated holding. Taking into account the fact that regulation of transfer pricing is also a tax regulation tool used by the state, the author emphasizes that the problems of transfer pricing tools aimed at tax risk management are not the object of the article. The results of the study can be used by employees and executives of corporate financial divisions, analysts, consultants, and employees of state agencies and authorities while developing the methodology for using financial instruments in company management.

Intro -- 1. Introduction - the arm's length principle -- 2. The first step: Value Chain Analysis (Christian Schwarz and Stefan Stein) -- 3. Transfer Pricing Methods -- 4. Comparability Analysis (Katharina Becker) -- 5. Supply of materials -- 6. Intangibles -- 7. Services -- 8. Cost Sharing Arrangements -- 9. Cost Contribution Arrangements -- 10. Business restructuring/transfer of functions -- 11. Financial Transactions -- 12. Tax challenges arising from the digitalisation of the economy -- 13. Permanent Establishments -- 14. Obligation to cooperate - Transfer pricing documentation -- 15. Country-by-Country Reporting -- 16. Litigation, dispute avoidance and resolution.

This comprehensive case intends to develop your understanding of the complexities involved in the international transfer pricing and taxation of intangible assets. The backdrop for the case is GlaxoSmithKline's $5.2 billion settlement in 2006 with the U.S. Internal Revenue Service. You are required to provide possible rationales for the positions advocated by the Company as well as the IRS. You are also required to present calculations under different transfer pricing methods, identify the most appropriate method, compute Foreign Tax Credits for different scenarios, and suggest possible strategies for multinational corporations to reduce the odds of negative settlements with tax authorities.

'Transfer pricing continues to be, and will remain, the most important international tax issue facing MNEs.' The term 'transfer pricing' is used to describe arrangements involving the transfer of goods or services, at an artificial price, in order to transfer income or expenses from one enterprise to an associated enterprise in a different tax jurisdiction. This results in the income derived at for each enterprise being disproportionate to their relative economic contributions, and thus impacting the relevant tax jurisdictions' fair share of tax. Tax authorities are therefore focusing their attention on transfer pricing rules and practices to ensure the correct attribution of income and expenses of related-party transactions. Another key issue, closely related to transfer pricing, is that of double taxation. Multinational enterprises, engaging in cross-border transactions, are at risk of having a single source of income taxed in two jurisdictions as a result of an incorrect application of transfer pricing rules. The purpose of this research is to evaluate South Africa's approach to transfer pricing, as well as compare it to the approaches as adopted by selected countries, namely Australia, the United Kingdom and Canada, with the aim of identifying the areas that South Africa could learn from practices in foreign jurisdictions. Specific issues dealt with include acceptable transfer pricing methods for determining an arm's length price, documentation requirements and non-compliance penalties, the use of Advance Pricing Agreements ("APA"), and the effects of e-commerce in applying the arm's length principle. The first issue relates to the criteria for the selection of the most suitable method in ensuring an arm's length outcome. Because the South African market is considered to be lacking in comparables, compliance with the arm's length principle will be determined by evaluation of the facts and circumstances of each case. The second issue looks at the transfer pricing policy documentation required to be prepared, the benefits of preparing such documentation, and the imposition of penalties on taxpayers failing to do so. The lack of statutory documentation requirements and specific penalty provisions in the South African legislation is also addressed. The third issue evaluates the use of APAs in resolving transfer pricing disputes. This technique is adopted by Australia, the United Kingdom and Canada, and therefore an assessment is made, taking into account both advantages and disadvantages of the technique, to determine whether it would be beneficial to South Africa to be able to agree in advance to transfer pricing methods to be applied to transactions with connected parties, thus reducing the potential for expensive and time consuming disputes with the South African Revenue Service ("SARS"). The fourth and final issue explores the challenges facing tax jurisdictions as a result of an increase in electronic trade. The relevance of the arm's length principle is assessed and recommendations for South Africa are made.