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The discussion in this section explains an economic theory behind optimal transfer pricing with optimal defined as transfer pricing that maximizes overall firm profits in a non-realistic world with no taxes, no capital risk, no development risk, no externalities or any other frictions which exist in the real world.
The Fund Transfer Pricing (FTP) measures the contribution by each source of funding to the overall profitability in a financial institution. [1] Funds that go toward lending products are charged to asset-generating businesses whereas funds generated by deposit and other funding products are credited to liability-generating businesses.
Whereas appropriate transfer pricing of tangible goods can be established by comparison with prices charged for similar goods to unrelated parties, transfer pricing of intangible goods, products of intellectual efforts, rarely has comparable equivalents. Transfer prices then have to be established based on expectations of future income. [16]
The transactional net margin method (TNMM) in transfer pricing compares the net profit margin of a taxpayer arising from a non-arm's length transaction with the net profit margins realized by arm's length parties from similar transactions; and examines the net profit margin relative to an appropriate base such as costs, sales or assets.
The specific functions and principles followed can vary based on the industry. Management accounting principles in banking are specialized but do have some common fundamental concepts used whether the industry is manufacturing-based or service-oriented. For example, transfer pricing is a concept used in manufacturing but is also applied in banking.
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Transfer pricing in the U.S. is governed by section 482 of the Internal Revenue Code (IRC) and applies when two or more organizations are owned or managed by the same interests. Section 482 applies to all transactions between related parties and commonly controlled parties, regardless of taxpayer intent, according to regulatory guidance.
Transfer Pricing Center: a comprehensive research tool featuring the latest OECD, U.S., and international transfer pricing rules, guidance, news, and analysis. The Tax Directory: a directory of corporate tax professionals in the U.S. and the government officials who write, implement, and interpret tax laws in the U.S. and abroad