Topic TRANSFER PRICING TRANSFER PRICING is a term used to describe all aspects of inter Company pricing arrangements between related business entities‚ and commonly applies to inter Company transfers of tangible and intangible property. Inter Company transactions across borders are growing rapidly and are becoming much more complex. Transfer pricing refers to the internal pricing system that is used when divisions in the same firm deliver products or services to each other. The transfer price
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CMA 302 – Tutorial Case Study: Final Draft Birch Paper Company 1. Background Birch Paper Company is a medium sized partly integrated company that produces Kraft papers and paperboard. There are four producing divisions and one timberland division which supplies part of the company’s pulp requirements. The divisions are - Northern Division - Southern Division - Thompson Division - Division 4 - Timberland Each
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Birch Paper 1 How would you resolve the transfer pricing conflict? Present calculations to support your arguments. The three bids (per thousand boxes) are as follows: Thompson division: $480 West Paper Company: $430 Eire Papers: $432 West Paper Company is the cheapest of the three although it is an outsider (as is Eire Papers). The manager of the Northern Division‚ William Kenton‚ should be allowed to buy from outside if the quoted price from the inside source is 10% over the
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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)
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Global transfer pricing guide More and more fiscal authorities continue to develop their transfer pricing laws. The principles are common‚ although interpretations differ from one tax authority to another. Compliance takes time and patience‚ and the demands and penalties from authorities are increasing. There is greater emphasis on examination and audit activity to encourage compliance and ignoring this issue is not an option for any well-run business. This international transfer pricing guide
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1. " Global Transfer Pricing: A Practical Guide for Managers "‚ Ralph Drtina‚ Jane L. Reimers‚ S.A.M. Advanced Management Journal‚ v74n2‚ Spring 2009. Transfer Pricing Article Summary The authors give a beneficial guide for managers for selecting and implementing a transfer pricing policy. According to the article‚ transfer pricing are the amounts charged for goods and services exchanged between divisions of the same company. In a multinational company strict international tax laws regulate
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cash flows associated with transfer pricing. In a decentralized firm‚ transfer prices generally play two important roles: 1. Allocate profits between different tax jurisdictions for taxation purposes 2. Coordinate economic activity within the firm Firms can choose to use different transfer prices for taxes and financial/internal reporting. The use of transfer prices allows central management to generate individual profit figures for different divisions. The transfer price is an expense on the
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Transfer Pricing In India 1 Transfer Pricing 2 a) What is transfer pricing? 2 2 Transfer Pricing in India 3 a) Definition 3 b) Associated enterprises 4 c) International transactions 4 d) Arm’s length transaction 4 1. Comparable uncontrolled price method 4 2. Resale price method 5 3. Cost plus method 5 4. Profit split method 6 5. Transactional net margin method (TNMM) 6 6. Any other method prescribed by the board 6 e) Maintaining Documentation 6
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Chapter 5 Transfer Pricing Methods [This paper is based on a paper prepared by Members of the UN Tax Committee’s Subcommittee on Practical Transfer Pricing Issues‚ but includes some Secretariat drafting and suggestions not yet considered by them – the Secretariat takes responsibility for any relevant errors and omissions. Formerly‚ Methods were dealt with in Chapters 4 and 5‚ which are now combined – hence the reference‚ on a temporary basis‚ to Parts 5A and 5B of this paper]. [Table of Contents to be added]
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Transfer Pricing in India 1. Introduction Increasing participation of multi-national groups in economic activities in India has given rise to new and complex issues emerging from transactions entered into between two or more enterprises belonging to the same group. Hence‚ it was pertinent to introduce a uniform and internationally accepted mechanism of determining reasonable‚ fair and equitable profits and tax in India in the case of such multinational enterprises. Accordingly‚ the Finance
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