Page 190 - International Marketing
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                             192                International Marketing          BRILLIANT'S

                                 1. Tax Savings: Imagine a company with two branches, where one
                             makes semi-finished goods in a low-tax country and exports them to a
                             branch in a high-tax country, where they are finished and sold. By increasing
                             the transfer price and declaring more of its profits in the low-tax country,
                             the company can reduce its global tax bill.
                                 2. Boost Profits: By  undercharging for goods crossing national
                             borders, a company can save money on customs duties paid by the branch
                             in the importing country. Conversely, by overcharging, a company can
                             extract more money from a country with tighter currency outflow restrictions.
                                 3. Measure  Performance: Companies need to  know how their
                             individual divisions are performing. A way of measuring that is through
                             transfer pricing. By setting a price for goods in each stage of the production
                             process, a company can measure the profitability of each division and
                             decide where to make organizational adjustments.
                                 4. Arm's Length Standard: The basic principle of this standard used
                             by most developed countries is that for transactions between branches a
                             company should use market prices. However, enforcement of this rule is
                             complicated, especially  when a company  has branches in  numerous
                             countries.
                                 5. Maintains Autonomy: Since, autonomy means decentralization
                             and freedom to make decisions, it is also an ingredient in motivating effort.
                             Managers may exert considerable effort in pursuing their own goals that
                             conflict with the goals of the firm. Central office interference in a transfer-
                             pricing dispute will affect autonomy and effort. The dilemma is that goal
                             congruent behavior  may not be obtained with or without interference.
                             Financial Aspects of International Transfer Pricing
                                 The transfer pricing can be adopted to minimize tax or import duty
                             liability or to transfer funds.
                                 1.  Transferring products into a high duty country at very low prices
                                     may result in low import duty.
                                 2.  Transferring products into a high tax country at high prices can
                                     effectively transfer profits from the high tax country to the low tax
                                     country.
                                 3.  Products may be transferred at high prices into a country from
                                     which dividend repatriation is restricted or subject to high tax.
                                 4.  It can avoid an accumulation of funds in a country with high infla-
                                     tion rates or where an early devaluation is thought to be a prob-
                                     ability or where expropriation is feared.
                                 5.  It can be used as a means to concentrate profits.
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