Evaluation of Transfer Pricing Policies

Transfer pricing refers to the setting of prices for goods sold between different entities within the same company, often located in different countries.

It is the process of determining the price of goods or services exchanged between various divisions or subsidiaries of the same business or organization, frequently spread across international borders.

For instance, imagine a multinational company with a production facility in Country A and a sales subsidiary in Country B. The production facility in Country A produces a product sold by the sales subsidiary in Country B. To set the transfer price for the product, the company must determine a fair price that reflects the value of the product as well as the costs of production and distribution.

Transfer pricing is crucial since it may have a big impact on taxes for both businesses and governments. The earnings made by each division or subsidiary, and consequently the taxes paid in each country, can be impacted by the transfer price a firm chooses to charge for goods or services.

Transfer pricing requires careful consideration and an expert assessment of the risks and rewards involved. It is not just a mechanical process; it involves several variables that require careful analysis and professional opinion.

The concept of transfer pricing is not new, but its application in practice is complex. In practice, transfer pricing can be used to transfer profits and costs among different divisions, divisions within the same group, groups within a parent company and even among different countries.

Transfer Pricing Policies

Transfer pricing policies are the guidelines and procedures that companies use to establish transfer prices for goods or services that are traded between different divisions or subsidiaries of the same company or group. Transfer pricing policies typically aim to comply with the arm’s length principle and applicable regulations, while also considering the company’s overall business objectives.

The company adopts transfer pricing policies based on evaluating the risks involved, asset use, and market conditions.

Cost Plus Method

The cost-plus method focuses on the related manufacturing department as the tested party in transfer pricing analysis. It begins with the cost incurred by the department, and markup is then added to this cost to make a reasonable profit because of functions performed, the risk assumed, and assets used. It is calculated with the help of the following formula:

Transfer Price = Cost + Markup for Selling Division

The cost-plus method is used to analyse transfer price issues that involve tangible property or service. It is most useful when it is applied to manufacturing or assembling activities. This method evaluates the arm-length nature of inter-department charges regarding the gross profit markup on costs incurred by the supplier department.

This method compares the gross profit markup earned by the department manufacturing the product to the gross profit markup point by other comparable departments. If we assume, the cost of manufacturing of department per unit comes to $5,000, and we assume the gross profit markup of the associate enterprise should earn is 50%. The resulting transfer price will be $5,000 + 50% of 5,000 = $7,500.

Fair Market Value Method

The Fair Market Value (FMV) method is one of the transfer pricing methods companies use to determine the appropriate price for goods or services traded between related entities. The FMV method establishes the transfer price as the price charged in an arm’s length transaction between unrelated parties for similar goods or services under similar circumstances.

This method can be applied if the product is salable as manufactured by the department without further processing. Under the fair market value method, the transfer price from one department to another is the product’s market price that the transferor department manufactures.

This method presumes that the transferor department has manufactured the goods and earned the company’s profit, assuming that the goods are sold in the market, and the transferee department purchases the article from the market. What will be the cost of the transferee department? This method justifies the performance of the transferor department and the transferee departments.

Price Negotiated by the Managers

Sometimes neither the cost plus markup price nor the market price is the transferred price of the product, but it is mutually decided by the managers of the transferor and transferee departments. The managers consider the transferor department’s cost and the reasonable profits that should be assigned to the transferor department for its efforts and utilisation of assets and risks borne by the department in manufacturing the product.

At the same time, the concerning cost to the transferee department is also considered so that the transferee department’s cost is not overstated. This method provides a better understanding and reduces conflict of interest between the managers of the transferor and transferee departments.

Significance of Transfer Pricing

Transfer price is significant from the point of view of departments. However, it does not affect the company’s overall profitability because the transfer price neutralises the effect of profits generated by the transferor department by cost increase for the transferee department.

But the transfer price used shows the efficiency of the transferor department for the generation of profits and also the efficiency of the manager of the transferee department for cost-effectiveness.

If the transfer is at cost, then the efficiency of the transferor and the transferee department managers cannot be evaluated. The manager of the transferor department will always be concerned about transfer pricing, which includes costs and higher profits.

On the other hand, the manager of the transfer department will be interested in transferring products at cost. Therefore, fixing transfer pricing is a key issue and is important in the company’s interest to motivate the managers.