Definition: Transfer price is the price at which one part of an entity sells a product or service to another part of the

same entity. There are a number of transfer pricing methods, such as using the market price, or a negotiated price, or cost plus margin. Transfer pricing is used to avoid paying income taxes in high-tax regions, and so is a significant focus of government auditing activities. Concept :1. Transfer price is defined as the value placed on transfer of goods or services among two or more profit centers. For selling profit center, the transfer price is major determinant of its revenue and hence its profits. For buying profit center, the transfer price is major determinant of the expenses incurred and hence its profit. The price of inter divisional sales affects the selling divisional sales and buying divisional cost. Transfer price is fundamentally an attempt to simulate external market condition within the organization.

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METHODS 1. Market-based Transfer Price

Market conditions which are appropriate for adoption Are generally appropriate in a perfect market, where there is homogeneous product with only one price for both sellers and buyers and no buying or selling costs. In a perfect market, Selling Division (SD) will be operating at full capacity and can sell whatever quantity of intermediate product it can produce in the external market. In this situation, internal transfers will result in a need to sacrifice external sales. The benefit forgone that is the contribution lost (opportunity cost) from sacrificing external sales should be included in the transfer price. Thus in this situation TP=MP will be consistent with the general TP rule. TP=MC+OC = MP In a perfect market, the minimum TP is also the maximum TP. Thus, both SD and BD will be happy with a transfer price set as the market price. The adoption of market-based transfer price in a perfectly competitive market meet the criteria of a good transfer price, that is it will promote goal congruent decisions, preserve divisional autonomy and provide an equitable basis for performance evaluation.

2. Full-cost based Transfer Price Market conditions which are appropriate for adoption In an imperfect market, it may be unwise to always set transfer price exactly at the variable costs of production, as such prices do not provide for the replacement of fixed assets. The Supply Division (SD) will want to base the transfer price on total absorption cost to ensure that it will provide a contribution to cover the fixed overheads. Full-cost based transfer price is widely used because managers require an estimate of long-run marginal cost for decision-making. However, traditional absorption costing systems tend to provide poor estimates of long-run marginal cost for decision-making. ABC will provide better estimates of long run MC. 3. Negotiated Transfer Price Market conditions which are appropriate for adoption In an imperfect market (different selling costs for internal and external sales, differential market prices), transfer prices set at the prevailing or planned market price are not optimal i.e. will not induce SD and BD to adopt optimal output level. Central/corporate management intervention is necessary in order to ensure that optimal output levels are set but this process may undermine divisional autonomy. In this situation, it is more appropriate to adopt negotiated transfer prices. If both managers had been provided with all the information and were educated to use information correctly, it is likely that a negotiated solution would have emerged which would have been acceptable to both the divisions and the group. When there is unused capacity, the transfer price range for negotiations generally lied between the minimum price at which SD is willing to sell (its marginal cost) and the maximum price BD is willing to pay (the external supplier price net off any external purchase related costs). Commercial transactions between the different parts of the multinational groups may not be subject to the same market forces shaping relations between the two independent firms. One party transfers to another goods or services, for a price. That price is known as transfer price. This may be arbitrary and dictated, with no relation to cost and added value, diverge from the market forces. Transfer price is, thus, a price which represents the value of good; or services between independently operating units of an organisation. But, the expression transfer pricing generally refers to prices of transactions between associated enterprises which may take place under conditions differing from those taking place between independent enterprises. It refers to the value attached to transfers of goods, services and technology between related entities. It also refers to the value attached to transfers between unrelated parties which are controlled by a common entity. EXAMPLE: Suppose a company A purchases goods for 100 rupees and sells it to its associated company B in another country for 200 rupees, who in turn sells in the open market for 400 rupees. Had A sold it direct, it would have made a profit of 300 rupees. But by routing it through B, it restricted it to 100 rupees, permitting B to appropriate the balance. The transaction between A and B is arranged and not governed by market forces. The profit of 200 rupees is, thereby,

shifted to the country of B. The goods is transferred on a price (transfer price) which is arbitrary or dictated (200 hundred rupees), but not on the market price (400 rupees). Thus, the effect of transfer pricing is that the parent company or a specific subsidiary tends to produce insufficient taxable income or excessive loss on a transaction. For instance, profits accruing to the parent can be increased by setting high transfer prices to siphon profits from subsidiaries domiciled in high tax countries, and low transfer prices to move profits to subsidiaries located in low tax jurisdiction. EXAMPLE of this, a group which manufacture products in a high tax countries may decide to sell them at a low profit to its affiliate sales company based in a tax haven country. That company would in turn sell the product at an arm's length price and the resulting (inflated) profit would be subject to little or no tax in that country. The result is revenue loss and also a drain on foreign exchange reserves

 If two or more profit center is jointly responsible for product development manufacturing and marketing each should share in the revenue that is generated when the product is finally sold.  The transfer price is not primarily an accounting tool; rather, it is a behavioral tool that motivates manager to make the right decisions.  In particular the transfer price should be designed so that it accomplishes the following objective:  It should provide each segment with the relevant information required to determine the optimum tradeoff between company cost and revenues.  It should induce goal congruent decisions that is the system should be so designed that decision improve business unit to earn more profit.  It should help measure the economic performance of the individual profit center.

Transfer pricing:
Definition:Transfer price is the price at which one part of an entity sells a product or service to another part of the same entity. There are a number of transfer pricing methods, such as using the market price, or a negotiated price, or cost plus margin. Transfer pricing is used to avoid paying income taxes in high-tax regions, and so is a significant focus of government auditing activities. BENEFITS

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Divisions can be evaluated as profit or investment centers. Divisions are forced to control costs and operate competitively. If divisions are permitted to buy component parts wherever they can find the best price (either internally or externally), transfer pricing will allow a company to maximize its profits.

Concept :1. Transfer price is defined as the value placed on transfer of goods or services among two or more profit centers. For selling profit center, the transfer price is major determinant of its revenue and hence its profits. For buying profit center, the transfer price is major determinant of the expenses incurred and hence its profit. The price of inter divisional sales affects the selling divisional sales and buying divisional cost. Transfer price is fundamentally an attempt to simulate external market condition within the organization.

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If two or more profit center is jointly responsible for product development manufacturing and marketing each should share in the revenue that is generated when the product is finally sold. The transfer price is not primarily an accounting tool; rather, it is a behavioral tool that motivates manager to make the right decisions. In particular the transfer price should be designed so that it accomplishes the following objective: It should provide each segment with the relevant information required to determine the optimum tradeoff between company cost and revenues It should induce goal congruent decisions that is the system should be so designed that decision improve business unit to earn more profit It should help measure the economic performance of the individual profit center

TRANSFER PRICING IS NOT AN ACCOUNTING TOOL Example: Take another case, a major public sector bank in India. It has a large number of branches where it collects deposits and makes small loans. Large corporate loans are made at the central office or at some major offices spread throughout the country. Branches earn interest from central office on the deposits that they garner (deposits are presumed to have been lent to central office) and pay interest to central office on loans they make - as deposits are lent to central office any loans made at branches obviously can be made only with funds borrowed from central office hence this interest. Transfer pricing (interest to and from central office here) was based on the costs branches incurred in developing business and in servicing deposits and loans. Each branch thus reported its periodic profit and loss figures. The counyry's central bank in course of a survey found that a large number of branches were running in loss. They instructed the bank to do something about it. Bank tweaked the transfer pricing rates and almost all branches started showing profits. Obviously such tweaking would not affect the bank's overall profitability. 5. Not long ago, transfer pricing was a subject for tax administrators and one or two other specialists. But recently, politicians, economists and businesspeople, as well as NGOs,

have been waking up to the importance of who pays tax on what in international business transactions between different arms of the same corporation. Globalisation is one reason for this interest, the rise of the multinational corporation is another. Once you take on board the fact that more than 60% of world trade takes place within multinational enterprises, the importance of transfer pricing becomes clear. Transfer pricing refers to the allocation of profits for tax and other purposes between parts of a multinational corporate group. Consider a profitable UK computer group that buys micro-chips from its own subsidiary in Korea: how much the UK parent pays its subsidiary the transfer price will determine how much profit the Korean unit reports and how much local tax it pays. If the parent pays below normal local market prices, the Korean unit may appear to be in financial difficulty, even if the group as a whole shows a decent profit margin when the completed computer is sold. UK tax administrators might not grumble as the profit will be reported at their end, but their Korean counterparts will be disappointed not to have much profit to tax on their side of the operation. This problem only arises inside corporations with subsidiaries in more than one country; if the UK company bought its microchips from an independent company in Korea it would pay the market price, and the supplier would pay taxes on its own profits in the normal way. It is the fact that the various parts of the organisation are under some form of common control that is important for the tax authority as this may mean that transfers are not subject to the full play of market forces. Transfer prices are useful in several ways. They can help an MNE identify those parts of the enterprise that are performing well and not so well. And an MNE could suffer double taxation on the same profits without proper transfer pricing. Take the example of a French bicycle manufacturer that distributes its bikes through a subsidiary in the Netherlands. The bicycle costs 900 to make and it costs the Dutch company 100 to distribute it. The company sets a transfer price of 1000 and the Dutch unit retails the bike at 1100 in the Netherlands. Overall, the company has thus made 100 in profit, on which it expects to pay tax. But when the Dutch company is audited by the Dutch tax administration they notice that the distributor itself is not showing any profit: the 1000 transfer price plus the Dutch units 100 distribution costs are exactly equal to the 1100 retail price. The Dutch tax administration wants the transfer price to be shown as 900 so that the Dutch unit shows the groups 100 profit that would be liable for tax. But this poses a problem for the French company, as it is already paying tax in France on the 100 profit per bicycle shown in its accounts. Since it is a group it is liable for tax in the countries where it operates and in dealing with two different tax authorities it cannot just cancel one out against the other. Nor should it pay the tax twice. Arms length In a bid to avoid such problems, current OECD international guidelines are based on the arms length principle that a transfer price should be the same as if the two companies involved were indeed two independents, not part of the same corporate structure. The arms length principle (ALP), despite its informal sounding name, is found in Article 9 of the OECD Model Tax Convention and is the framework for bilateral treaties between OECD countries, and many nonOECD governments, too.

The OECD Transfer Pricing Guidelines provide a framework for settling such matters by providing considerable detail as to how to apply the arms length principle. In the hypothetical French-Dutch bicycle case, the French MNE could ask the two tax authorities to try to reach agreement on what the arms length transfer price of the bicycles is and avoid double taxation. It is likely that the original transfer price set by the MNE was wrong because it left all the profit with the manufacturer, while the Dutch proposal erred on the other side by wanting to transfer all the profit to the distributor. But all of this assumes the best possible world, where tax authorities and MNEs work together in good faith. Yet transfer pricing has gained wider attention among governments and NGOs because of another risk: that it could be used to shift profits into low tax jurisdictions even if the MNE carries out little business activity in that jurisdiction. This leads to trade distortions, as well as tax distortions.

No country poor, emerging or wealthy wants its tax base to suffer because of transfer pricing. That is why the OECD has spent so much effort on developing its Transfer Pricing Guidelines. While they help corporations to avoid double taxation, they also help tax administrations to receive a fair share of the tax base of multinational enterprises. But abuse of transfer pricing may be a particular problem for developing countries, as companies might take advantage of it to get round exchange controls and to repatriate profits in a tax free form. The OECD provides technical assistance to developing countries to help them implement and administer transfer pricing rules in a broadly standard way, while reflecting their particular situation. Applying transfer pricing rules based on the arms length principle is not easy, even with the help of the OECDs guidelines. It is not always possible and certainly takes valuable time to find comparable market transactions to set an acceptable transfer price. A computer chip subsidiary in a developing country might be the only one of its kind locally. But replacement systems suggested so far would be extremely complex to administer. The most frequently advocated alternative is some kind of formulary apportionment that would split the entire profits of an MNE among all its subsidiaries, regardless of their location. But proponents of such alternatives not only have to show that their proposals are theoretically better but that they are capable of winning international agreement. Not easy, since the very act of building a formula makes it clear what the outcome is intended to be and who the winners and losers will be for a given set of factors. Tax authorities would naturally want the inputs to reflect their assessment of profit. Questions like how to apportion intellectual capital and R&D between jurisdictions would become contentious. Such problems would make it very difficult to reach agreement on the inputs to the formula, particularly between parent companies in wealthy countries and subsidiaries in poorer ones. ALP avoids these pitfalls as it is based on real markets. It is tried and tested, offering MNEs and governments a single international standard for agreements that give different governments a fair share of the tax base of MNEs in their jurisdiction while avoiding double taxation problems. Moreover, it is flexible enough to meet new challenges, such as global trading and electronic

commerce. Governments so far appear to agree: much better to update the existing system than start from scratch with something new