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Kaplan Transfer Pricing – International Issues

Forums › ACCA Forums › ACCA APM Advanced Performance Management Forums › Kaplan Transfer Pricing – International Issues

  • This topic has 4 replies, 4 voices, and was last updated 11 years ago by John Moffat.
Viewing 5 posts - 1 through 5 (of 5 total)
  • Author
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  • April 14, 2014 at 6:20 pm #165282
    deepmaharaj
    Member
    • Topics: 58
    • Replies: 32
    • ☆☆

    A multinational Organization C has 2 divisions each in different country -Divisions A and B . Suppose Division A produces a product X where the domestic income tax rate is 40% and transfers it to Division B , which operates in a country with 50% rate of income tax. An import duty equal to 25% of the price of product is X is also assessed . The full Cost per unit is 190 and Variable Cost is 60
    Required The tax authorities allow either variable or full cost transfer prices. Determine which should be chosen.
    Kapalan Answer
    Effect of Transferring at 190 instead of 60
    Income of A is higher and so A pays 130 X 40% more income tax = (52)
    Income of B is 130 $ lower and so C pays 130 X 50% Less income tax = 65
    Import duty is paid at 25% = (32.5)
    Net Effect ( Cost) of transferring at 190 instead of 60 (19.5)
    Conclusion – C should transfer at variable cost
    ==================================================================
    1) This answer is beyond my comprehension. When transferring at full cost ( 190) how income gets increased by 130.
    2) Thumb Rule is let the division in the country where income tax is to lesser extent ( 40% at A) makes maximum profit so that It pays less than ( B where it is 50%)
    3) Why they have taken import duty into account – It has to be paid whether transfer by variable cost or full cost.
    So answer should be let transfer be at full cost Not at Variable Cost.
    Kindly make me understand this.
    Deepak

    April 15, 2014 at 6:36 am #165313
    deepmaharaj
    Member
    • Topics: 58
    • Replies: 32
    • ☆☆

    Dear Sir

    I think this Import Tariff at 25% is creating skewed presentation. If we consider only 40% Tax and 50% Tax in Country A and Country B respectively by leaving out Import Tariff at 25%. It is going in favour of full transfer price – leaving maximum profit in Country A and saving profit from tax where tax rates are high 50% -in Country B.
    But by taking this import tariff of 25% into account – then it makes a case for transfer at variable cost just to save Group from paying higher tariff on full transfer price.

    Kindly correct me, If I am wrong

    Deepak

    April 17, 2014 at 7:28 am #165503
    acca13
    Member
    • Topics: 57
    • Replies: 175
    • ☆☆☆

    Hmmmm

    April 17, 2014 at 12:37 pm #165531
    hafiz
    Member
    • Topics: 1
    • Replies: 17
    • ☆

    yes

    April 17, 2014 at 1:07 pm #165536
    John Moffat
    Keymaster
    • Topics: 57
    • Replies: 54682
    • ☆☆☆☆☆

    I am not the tutor for P5, but if you are wanting an answer from a tutor then you should be posting the question in the Ask the ACCA Tutor forum.

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