ManagementParadise.com : Worlds Leading Management Portal. MBA | Classroom, Boardroom and Beyond


Go Back   ManagementParadise.com Forums - Your MBA Online Degree Program and Management Students Forum for MBA,BMS, MMS, BMM, BBA, students & aspirants. > Projects HUB for Management Students ( MBA Projects and dissertations / BMS Projects / BBA Projects > Resolve Your Query - Get Help and discuss Projects > Marketing Management ( RM , IM )

Transfer Pricing

Transfer Pricing

Discuss Transfer Pricing within the Marketing Management ( RM , IM ) forums, part of the Resolve Your Query - Get Help and discuss Projects category; Transfer pricing refers to the setting, analysis, documentation, and adjustment of charges made between related parties for goods, services, or ...

Reply

 

LinkBack Thread Tools Display Modes
Advertisements
Transfer Pricing
Old
 (1 (permalink))
Sunanda K. Chavan
sunandaC has a spectacular aura aboutsunandaC has a spectacular aura aboutsunandaC has a spectacular aura about
 
sunandaC
Management Paradise Guru
 
Status: Offline
Posts: 6,685
Join Date: Jul 2010
Transfer Pricing - November 3rd, 2011

Transfer pricing refers to the setting, analysis, documentation, and adjustment of charges made between related parties for goods, services, or use of property (including intangible property).

Transfer prices among components of an enterprise may be used to reflect allocation of resources among such components, or for other purposes. OECD Transfer Pricing Guidelines state, “Transfer prices are significant for both taxpayers and tax administrations because they determine in large part the income and expenses, and therefore taxable profits, of associated enterprises in different tax jurisdictions.”
Over 60 governments have adopted transfer pricing rules.

Transfer pricing rules in most countries are based on what is referred to as the “arm’s length principle” – that is to establish transfer prices based on analysis of pricing in comparable transactions between two or more unrelated parties dealing at arm’s length. The OECD has published guidelines based on the arm's length principle, which are followed, in whole or in part, by many of its member countries in adopting rules. The United States and Canadian rules are similar in many respects to the OECD guidelines, with certain points of material difference.

A few countries, such as Brazil and Kazakhstan, follow rules that are materially different overall.

The rules of nearly all countries permit related parties to set prices in any manner, but permit the tax authorities to adjust those prices where the prices charged are outside an arm's length range. Rules are generally provided for determining what constitutes such arm's length prices, and how any analysis should proceed.

Prices actually charged are compared to prices or measures of profitability for unrelated transactions and parties. The rules generally require that market level, functions, risks, and terms of sale of unrelated party transactions or activities be reasonably comparable to such items with respect to the related party transactions or profitability being tested.

Most systems allow use of multiple methods, where appropriate and supported by reliable data, to test related party prices. Among the commonly used methods are comparable uncontrolled prices, cost plus, resale price or markup, and profitability based methods. Many systems differentiate methods of testing goods from those for services or use of property due to inherent differences in business aspects of such broad types of transactions. Some systems provide mechanisms for sharing or allocation of costs of acquiring assets (including intangible assets) among related parties in a manner designed to reduce tax controversy.

Most tax treaties and many tax systems provide mechanisms for resolving disputes among taxpayers and governments in a manner designed to reduce the potential for double taxation. Many systems also permit advance agreement between taxpayers and one or more governments regarding mechanisms for setting related party prices.

Many systems impose penalties where the tax authority has adjusted related party prices. Some tax systems provide that taxpayers may avoid such penalties by preparing documentation in advance regarding prices charged between the taxpayer and related parties. Some systems require that such documentation be prepared in advance in all cases
Advertisements
Friends: (0)
Reply With Quote
Related to Transfer Pricing
 

Similar Threads

Thread Thread Starter Forum Replies Last Post
Transfer Pricing Manish V Dhanwani Miscellaneous Project Reports 7 October 29th, 2010 02:40 PM
Transfer Pricing Abhijeet S Financial Management ( FM ) 0 September 8th, 2010 07:23 PM
TRANSFER PRICING Purshottam Tiwari Financial Management 13 March 15th, 2009 09:13 PM
Transfer Pricing chappu Financial Management 1 September 25th, 2008 07:37 PM
Transfer pricing case Purshottam Tiwari Articles !! 1 October 14th, 2006 04:57 PM
 

Reply

Bookmarks

Tags
pricing, transfer

Thread Tools
Display Modes

Posting Rules
You may not post new threads
You may not post replies
You may not post attachments
You may not edit your posts

BB code is On
Smilies are On
[IMG] code is On
HTML code is On
Trackbacks are On
Pingbacks are On
Refbacks are On


» Login
Forgot Password?  New User?
  

» Ads





» Recent Threads

Epic Research Update :...
Last post by Epic Research
2 Hours Ago 04:24 PM
1 Replies
Epic Research Update :...
Last post by Epic Research
2 Hours Ago 04:20 PM
1 Replies
Can facebook can be used... ( 1 2 3)
Last post by Kiky Idforq
3 Hours Ago 03:20 PM
29 Replies
Indians Perform Better...
Last post by Kiky Idforq
3 Hours Ago 03:18 PM
3 Replies
Hard work or Smart work... ( 1 2)
Last post by Kiky Idforq
3 Hours Ago 03:17 PM
14 Replies
Should tobacco companies...
Last post by Kiky Idforq
3 Hours Ago 03:15 PM
4 Replies
Are english skills...
Last post by Kiky Idforq
3 Hours Ago 03:14 PM
7 Replies
Wisdom does not come...
Last post by Kiky Idforq
3 Hours Ago 03:12 PM
3 Replies
Download more than 300...
Last post by Abhaya Panda
5 Hours Ago 01:30 PM
3 Replies
Happy Dhanteras Quotes,...
Last post by Krunal Dhabhi
8 Hours Ago 10:51 AM
1 Replies
Solution manual on...
Last post by Andrew Ken
12 Hours Ago 06:35 AM
1 Replies
Marketing Strategies for... ( 1 2 3)
Last post by Waheed Jan
20 Hours Ago 10:26 PM
24 Replies
International Marketing ( 1 2 3... Last Page)
Last post by Waheed Jan
21 Hours Ago 09:54 PM
77 Replies
Top 5 Beautiful Rangoli...
Last post by Dharmik Moni
22 Hours Ago 08:44 PM
2 Replies
Diwali latest Rangoli...
Last post by Dharmik Moni
22 Hours Ago 08:43 PM
2 Replies

» Projects Helpline

Solution manual on...
Last post by Andrew Ken
12 Hours Ago 06:35 AM
Stock Marketing TYBMS...
Last post by Rajat Audichya
5 Days Ago 05:42 PM
CRM- Hotel Industry
Last post by Matt Martin
5 Days Ago 10:32 PM
advertising in telecom...
by kpis_02
Last post by Mohit Utmani
6 Days Ago 10:45 AM
ManagementParadise.com is not responsible for the views and opinion of the posters. The posters and only posters shall be liable for any copyright infringement.


Management Paradise
About Us
Press
Jobs
Contact Us
Kartik Raichura
Legal
Terms & Conditions
Privacy Policy
Disclaimer
Copyrights
Help
Zeitgeist
Support
FAQs
Tour
Feedback
Partners
Follow
Copyright © 2004 - 2013 Management Paradise. Site Developed by Available.co.in