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Transfer Pricing

Forums › Ask ACCA Tutor Forums › Ask the Tutor ACCA AFM Exams › Transfer Pricing

  • This topic has 3 replies, 2 voices, and was last updated 8 years ago by John Moffat.
Viewing 4 posts - 1 through 4 (of 4 total)
  • Author
    Posts
  • November 16, 2016 at 12:39 pm #349246
    dewan
    Member
    • Topics: 22
    • Replies: 167
    • ☆☆

    Hi john.How are you?Hope doing well. I got few issues regarding Transfer pricing which i have listed below.
    Ques. Suppose Company X is based in Uk and it has got a subsidiary Y in France.Y is required to remitt 80% profit to X. Full credit is given by UK tax authorities for tax paid overseas.
    Corporation Tax: UK=30%, France =25%
    Profit before tax(PBT) of Y= $100,000.(We assumes we deal in dollars)
    Witholding tax of 5% needs to be paid by Y for any remittance.
    So my thought process dealing the question is below,
    PBT of Y =$100000
    Tax paid@25% =(25000)
    Profit after tax =$75000
    Remittance to UK= $ 60000
    Witholding tax = $ (3000)
    Profit retaied by Y=$15000( Which is 20% of PAT)
    FOR X though,
    They received = $55000(Net of witholding tax)
    Extra tax to be paid =$( 3750)
    (75000*.05%)
    Net Cash flow from =$ 51250
    ( Y )
    Am i correct on this John? I am confused like Do X will get any tax credit for witholding tax paid by Y on the X remittance so basically Y is paying 25%+5%=30%.So there should not be extra 5% paid by X to uk tax authorities.Or we assume X don’t get tax credit for any witholding tax paid by Y and the the above procedure i mentioned is correct.
    Thank you.

    November 16, 2016 at 5:53 pm #349328
    John Moffat
    Keymaster
    • Topics: 57
    • Replies: 54700
    • ☆☆☆☆☆

    It seems you are right at a quick look, but I am sorry – I really do not have the time to work through it all in great detail.

    November 17, 2016 at 3:35 am #349423
    dewan
    Member
    • Topics: 22
    • Replies: 167
    • ☆☆

    Ok no worries.Thanks a lot John.

    November 17, 2016 at 7:22 am #349480
    John Moffat
    Keymaster
    • Topics: 57
    • Replies: 54700
    • ☆☆☆☆☆

    You are welcome 🙂

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    Posts
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