Matter & Substance
  February 5, 2024

Transfer Pricing Methods & Strategies for Your Multinational Business

Navigating the complexities of transfer pricing is a critical aspect of managing a multinational business. This practice involves determining the prices at which goods, services, and intellectual property are exchanged between affiliated entities within the same company. In this comprehensive guide, we explore the fundamentals of transfer pricing, its purposes, benefits, and drawbacks. Additionally, we delve into various strategies and methods used to establish transfer prices, providing insights into effective management.

What Is Transfer Pricing?

Transfer pricing is the setting of prices for goods, services, or intellectual property transferred between entities within the same multinational company. It aims to ensure that transactions between these affiliated entities reflect fair market values, preventing tax evasion and maintaining a transparent and equitable financial landscape.

How Does Transfer Pricing Work?

Transfer pricing works by establishing prices for intercompany transactions that mirror prices that would be charged between unrelated, independent entities. This practice is essential for tax purposes, as it helps prevent companies from manipulating prices to shift profits and tax liabilities across jurisdictions.

What Is the Purpose of Transfer Pricing?

The primary purpose of transfer pricing is to align the economic substance of transactions between related entities with their legal form. By doing so, transfer pricing ensures that profits are appropriately allocated among different jurisdictions, preventing tax avoidance and promoting a fair distribution of taxable income.

What Are the Benefits of Transfer Pricing?

  • Tax Compliance
    Transfer pricing facilitates compliance with tax regulations in various jurisdictions by ensuring that profits are accurately reported in each country.
  • Improved Resource Allocation
    By accurately reflecting the value of goods, services, and intellectual property, transfer pricing helps in optimal resource allocation and strategic decision-making.
  • Enhanced Global Operations
    Multinational companies benefit from smoother operations across borders as transfer pricing minimizes the risk of tax-related disputes.

What Are the Disadvantages of Transfer Pricing?

  • Complexity and Compliance Costs
    Managing transfer pricing can be complex and may involve significant compliance costs, particularly in adhering to different tax regulations.
  • Potential for Disputes
    Differences in interpretations and regulations across jurisdictions can lead to disputes with tax authorities, requiring careful management.
  • Risk of Penalties
    Inaccurate transfer pricing documentation may result in penalties, emphasizing the need for precise compliance.

What Strategies Might Be Used to Determine a Transfer Price?

Several strategies are employed to establish transfer prices, with each method tailored to specific business scenarios. These strategies help multinational companies adhere to the arm's length principle, ensuring that transactions between related entities are conducted at fair market values.


5 Transfer Pricing Methods

Choosing the appropriate method depends on the nature of the transactions and industry specifics, allowing businesses to align their transfer pricing practices with regulatory requirements and optimize their global operations. Below are five methods a business may look at:

  1. Comparable Uncontrolled Price (CUP)

    The CUP method involves comparing the price charged for a product or service in a controlled transaction with the price charged for a similar product or service in an uncontrolled transaction. This method relies on external market data to determine an arm's length price.

  2. Cost Plus Method (CPM)

    In the Cost Plus Method, the seller adds a markup to the costs of producing a product or providing a service. This markup represents the profit margin that an independent seller would seek in a comparable transaction.

  3. Resale Price Method (RPM)

    The RPM involves determining the resale price of goods or services by applying a gross margin to the purchase cost. This method is commonly used in retail or distribution scenarios.

  4. Transactional Net Margin Method (TNMM)

    The TNMM compares the net profit margin of a tested party in a controlled transaction with the net profit margin of comparable uncontrolled companies engaged in similar transactions.

  5. Profit Split Method (PSM)

    The Profit Split Method allocates profits between associated enterprises based on the division of profits that independent enterprises would have agreed upon in comparable transactions.

Examples of Transfer Pricing

Accurate transfer pricing is essential for tax compliance, risk mitigation, and strategic decision-making in the context of international business operations. Consider the following examples:

Example 1

Consider a multinational technology company that manufactures electronic components in Country A and sells them to its subsidiary in Country B. The transfer price is set based on the market value of similar components, ensuring that profits are appropriately allocated between the two entities.

Example 2

In the pharmaceutical industry, a company may transfer the rights to a patented drug developed in one country to a subsidiary in another country. The transfer price is established by comparing the licensing fees for similar drugs in the market.

Example 3

A multinational retail corporation may use the Resale Price Method to set transfer prices for products sold by its subsidiaries. The resale price is determined by applying an appropriate gross margin to the purchase cost, ensuring fair pricing.

Contact Mowery & Schoenfeld for Help Navigating Transfer Pricing

If you're seeking expert guidance on transfer pricing to enhance your multinational business's financial strategies, contact Mowery & Schoenfeld today. Our dedicated team is committed to helping you make informed decisions, maintain tax compliance, and maximize the benefits of effective transfer pricing. Unlock the full potential of your global operations with the support of Mowery & Schoenfeld's comprehensive international financial expertise.

Contact Us