Tuesday, October 16, 2012

Transfer pricing: inter-company charges/ inter-company sales or purchases/ management fees/

Transfer pricing is a hot topic among accountant in almost every countries. Transfer pricing become a significant topic following the globalization foot-step, where cross-border transactions become more and more common. Your audit client may have a head office in Singapore, a packaging plant in Malaysia, while a main manufacturing plant in China. The supply chain of the audit client can span accross different countries.

Of course, when a inter-company / related company rendered service for other inter-companies / related companies, a price will be charged. The question is: how much to be charged? on what basis should the audit client determine the pricing / gross margin ( in circumstances of cost plus company) on inter-company transactions.

It is important for us to highlight to client to have a basis on determining the inter-company charges (including: sales transaction, purchase transaction). The inter-company transactions should be conducted on an arms length basis (i.e. the pricing should not differ materially from the market price). This is because local tax authority is concern on potential tax manipulation to record higher margin at lower tax rate country / region.

Hence, a proper documentation on transfer pricing is important to support all inter-company transaction. Management should always make reference to market price to assess if transfer pricing is conducted on an arms length basis.

In addition, it is common for holding company / other entities within the Group to charge managment fee to other inter-companies for certain centralised function  (e.g. shared service centre)/ corporate service. Likewise, a proper documentation and computation is required to support the basis of determining the management fee.

As auditor , we need to understand the basis of management in coming up the transfer pricing documentation and  to reivew for high level reasonableness.

4 comments:

Dexter Morgan said...

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morrisaccounting tax return brisbane said...

This is very interesting and useful. You should write more, keep up the good work.

morrisaccounting tax return brisbane said...

This is very interesting and useful. You should write more, keep up the good work.

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