Transfer Pricing
Introduction:
When Investment Centers have been established, these would be considered as autonomous units. They would be free to purchase their raw materials direct from the market or from their own departments. In case of the latter, there are many advantages like (i) it would be cheaper to buy from own departments, (ii) there would be more quality assurance and reliability. Also, it would be beneficial to the selling department because (i) there would no packing and external transportation costs, and (ii) there would be no bad debt.
Why Transfer Pricing?
Chief Executive of a big company cannot monitor and control operations of each and every sub-unit. So the sub-units are turned into Investment Centers and necessary authority is delegated to their managers.But in a decentralization, there are difficulties in evaluating the performance of the managers. Further, there is a problem of coordination. So a method is needed to ascertain contribution of each sub-unit to the total profit of the organization. A common solution to this problem is to set prices for intermediate goods which are transferred from one division to another. These prices are known as transfer prices to be used for:
- Performance evaluation of each manager based on the contribution made by the sub-unit.
- Coordination of all sub-units for achieving the organisational goals.
- Deciding what to charge for transfer a product or service to the next department.
- to preserve autonomy of a sub-unit.
- Motivation of the managers as they would certainly get rewards for good performance through a transparent system.
Methods of Transfer Pricing
1) EXTERNAL MARKET PRICE
- If an external price is available, it would be a good price indicator. The transfer price should be the same as market price less an amount representing savings in packing and transportation cost etc.
- In an ideal situation, a sub-unit would have an option to sell directly to the maket should a reasonable transfer price is not agreed upon. Same is the case with the buying department.
2) COST PLUS MARKUP
- Sub units can fix a markup on cost to get a reasonable return which would enable them to achieve the required ROI. Such a markup may be based on variable cost or full cost. It would make no difference except that basing on variable cost would be convenient.
- Supposing variable and full costs of a department are Rs.300 and Rs.500 respectively. Suppose further that the manager thinks a fair price for his or her product to be Rs.600. So in case of variable cost, the markup would be 100% and in case of full cost 20%. Same results would be achieved in both the cases.
3) NEGOTIATED PRICES
- If there is no outside market, the buying and selling department may negotiate prices.
When group companies produce products that are used within the group, transfer price is established with an aim to optimise the group performance, although it may hurt the selling or the buying company within the group.
An issue that is often ignored is that whether this practice undermines the interest of minority shareholders. If there is no minority shareholder in the company that is hurt, the ethical/corporate governance issue does not arise. Otherwise, this is an important issue and need to be addressed by the board of directors of individual companies.
For multinational corporations, it may be advantageous to arbitrarily select prices such that most of the profit is made in a country with low taxes, thus shifting the profits to reduce overall taxes paid by a multinational group.
However, most countries enforce tax laws based on the arm's length principle as defined in the OECD (Organisation for Economic Co-operation and Development) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, limiting how transfer prices can be set and ensuring that that country gets to tax its "fair" share. In India, the OECD principle was adopted in 2001.
Applying transfer pricing rules based on the arm's length principle is not easy, even with the help of the OECD's guidelines. It is not always possible – and certainly takes valuable time – to find comparable market transactions to set an acceptable transfer price.
The revenue authority and the MNCs should work together in good faith to implement regulations effectively. The question of ethics cannot be ignored even in tax planning.
Summary
A good accounting system should promote goal congruence among its employees. In other words, all employees should work and take decision keeping in view objectives of the company. Various techniques have been used for this purpose such as Management By Objectives. The accounting system can make its contribution by segregating profitability of each division or sub division through declaring each division as an Investment centre.
ROI, RI and EVA are used as performance indicators but the transfer mechanism has to be addressed. An example was given of a Packaging Company. While its Package Unit sells in the market and earns revenues, this was not the case when paper was transferred to Printing Unit and printed sheets were passed on to Packaging Division. Here comes the question of Transfer Pricing. As a general rule, a transfer price should be equal to opportunity cost for the product.
With a sound system of Transfer Pricing, it become easy to prepare unit wise P&L account and to observe non-financial factors to evaluate performance of an individual unit. With such a transparency and accountability, overall results of company would be smooth achieving targets set at the start of the year.
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