¡@¡@This paper studies the MNE¡¦s choice of the optimal transfer price with the consideration of the possibility of transfer pricing penalty. Because the transfer prices are determined in-house, there are opportunities for MNE to manipulate the prices and evade corporate income tax and trade taxes. To reduce these opportunities, most governments have implemented transfer pricing regulations based on the OECD guidelines. If the MNE¡¦s manipulation of transfer prices is too flagrant, an extra tax will be levied to penalize the MNE. As long as the tax rates are different in different jurisdictions, the MNE will pick transfer prices that balance between the gain from profit shifting and the loss coming from the possible penalty. ¡@¡@Three forms of probability are introduced to capture the possibility of being penalized when the MNE tries to manipulate the transfer prices. We find close form solutions under the linear and quadratic forms of probability. And numerical simulation is used to get the optimal transfer price under the exponential form of probability.

Calculation of transfer prices of the individual performance means the calculation of the price of a product, service, work or other kind, expressed unit of output. Kind is usually expressed in the unit such as hours, kolograms, etc. The transfer price is a toll that is used for performance appraisals for the centers but is also used for other awards such as repair services, etc. This price is determined on the basis of precalculation. In the precalculation are listed the estimated cost of the product and the calculation shall be drawn up before the start of production, repectively at the beginning of the period. Individual performance is generally defined as the results of operations and as an external performance and internal performance. External performance are services such as goods, services or goods that are sold to consumers in the market at market prices. Internal performance are those services that are transmitted in particular within the enterprise between departments.

The purpose of this study is to answer the research question of how a service company (ServiceCo) could achieve a transfer price of its services. This is of particular interest, due to the growth of service firms that have rapidly increased and surpassed the manufacturing firms, as well as the dominant logic shifting towards services. However, the problem with this field of study is that transfer pricing with regards to the service industry, is a rather unexplored phenomenon in which the guidelines and theories are mostly directed towards manufacturing firms. This study uses a single case study approach where ServiceCo’s organizational characteristics were analyzed in order to attain the information required to understand how ServiceCo could achieve a transfer price of its services. Furthermore, this study uses the Eccles (1983) MAP and the OECD Guidelines, as well as incorporating Porter’s (1985) value chain. This study assesses that ServiceCo, in its current state, uses a sub-optimal transfer pricing method of its services. Therefore, a change in the transfer pricing method was suggested to ServiceCo. Given the organizational characteristics of ServiceCo, the results led to the conclusion that ServiceCo could benefit from a residual analysis in the profit split method, in which an actual full cost plus mark-up compensation could be used on its routine functions, and the residual profit could be split between the entities based on the intangible assets employed, functions performed and the risks carried.

The most common approach towards transfer pricing has been purely economic or with focus on tax regulations. However, transfer pricing has developed to become a component of organizational strategy. This indicates a growing focus on transfer pricing from a managerial perspective. A well-functioning transfer pricing structure can enable increased operational efficiency. The purpose of this paper is to explain the alignment between transfer pricing methods and strategy. The alignment between corporate levels and divisions enhances a corporation’s possibility to obtain strategic congruence, and thereby competitive advantage to become a stronger player on the market. The research is conducted as a multi-level case study with both qualitative and quantitative data collection. The result stresses that the case firms transfer pricing design is based on managerial objectives, and uses market-based and negotiated transfer price policies. The result finds that the methods and the strategy are partly aligned, which contributes to the corporation’s overall performance. Although, due to the levels different perceptions of profit maximization some sub-optimization occurs.

Following work focuses on the issue of transfer prices and evolution of the approach to such in a surveyed company in a spam of two years. In the first part, the author describes the status from the points of legislative changes and a common perception of transfer prices both in the Czech Republic and internationally. Second part relates to a specific condition in a surveyed company during authors bachelor studies and a third part describes the changes that had taken place in this company. The author focuses on the options of eliminating the risk of transfer prices by setting the set of inter-company guidelines. Next she is taking a more thorough look at the sale of goods, as it is the most common business relation between related parties. This work should be considered as a guide to a proper management of inter-company structure. It should help in determining a transfer pricing method and preparing a documentation related to transfer prices.

This thesis is focused on the sale of the enterprise between related persons. The ambition was to find out, what the tax aspects of a particural transfer of an existing company are, especially with regard to the payment of personal and corporate income tax rate. Partial aim was to determine market value of the enterprise as per January 1st 2010 for the transfer price purposes and structuring of the whole transaction with emphasis on rational tax optimalization. At first there is a valuation report elaborated with regard to the market environment. The price is set based on the DCF entity method. Consequently I work with the enterprise value analysing tax impacts. The transaction structure is chosen as setting up of a new company for leveraged buyout (SPV, s.r.o.) and subsequent merger of this company with the target company as per January 1st 2010. It was found out that the impact of the transfer price on the income tax is at this transaction minimal. In the particural structured transaction there are four kinds of tax risks. First are the rules of thin capitalization which the buyer is able to fulfil by the increase of its own capital at SPV, s.r.o. The second one is the assesment of interests on the affinitive credits according to the arm's length principle. The third one is check of costs of the acquisition credit which should be tax deductible with regard to the company merger. The last risk is the proof of accomplishment of general rules of costs (interest) tax deduction, i.e. the costs must be spent on achievement, securing and maintenance of taxable incomes. At the close of the thesis I focus on the motives of the related parties of the transaction for setting the price of the company. I assume that both parties would have tendencies to decline the enterprise value mostly because of the possibility of compensation through the gratuitous acquisition of asset which in this case in the legal environment of the Czech Republic enjoys the tax-free status.

The objective of the thesis is to design a management accounting system for a manufacturing company operating in the construction industry. As part of the proposed system new economic and cost structure will be created and described. Furthermore, the principles of valuation of internally transfered outputs will be based on a new system of transfer prices which will help to set up an internal profit and loss analysis for each cost center. Last part of the thesis is dedicated to problematics of calculation in which cost allocation principles will be described and displayed in a form of a custom made calculation formula.

Title: An athlete as a subject of the international bussines and the proces of the price building Objectives: My objectives for this Theses is to work on the the problematics of international transfer of athletes from club to club in soccer and ice hockey; and also evaluation of each aspect of the transfer, athletes values and their market price. Metods: In making of this Theses I used a method of description and theoretic reflection. To get more information I used the method of an interview. Results: Theses contains of information gathered from available literature connected with mentioned problematics along with information collected from my interviews with experts in sport industry. They together give us a new better way of explaining main principles of the "athlete transfer market". In my theses I am taking a closer look at all the factors of the "transfer price" of an athlete as well as the "price building module", especially its use in practice. The obtained benefit from my theses is a comprehensive view on the athlete transfers and the way of building their price. Key words: soccer, ice hockey, athlete pricing, value of and athlete, transfer price, price. Powered by TCPDF (www.tcpdf.org)

Made available in DSpace on 2016-04-25T18:40:29Z (GMT). No. of bitstreams: 1 Juliana Andressa Negri.pdf: 713550 bytes, checksum: 3ce036569070560c006397d64e4d4af4 (MD5) Previous issue date: 2008-05-12 / The transfer price is a managerial tool with the purpose of coordinating the decisions of a company in the reach of their goals, through a fastened value. It includes the operations of sales or the products transfers, services, being present in decentralized units, in other words, companies that chose for their organizational fragmentation, dividing their fastened structure in areas of businesses. In this context, the main objective of this work was to verify the importance of the transfer pricing used in the decentralized units of a agroindustrial cooperative, studying their procedures, as well as the treatment and identification of the methodology adopted in that inside sale process in the reception divisions and refine of the soy. This way, through a case study, it was tried to identify the participation of the decentralized units in the result of the agroindustrial cooperative of the north of Paraná, and the inside transfer pricing adopted by this organization. Therefore, it is concluded that the performance of each one of the units affects in a direct way the final result of the company, although each responsibility center adopts a pricing mechanism in keeping with their activities. The importance of the administration of the transfer price optimizes this process in a positive way; however it is compacted or very close to the costing ways, harming, consequently, its work as a performance measurer / O preço de transferência é uma ferramenta gerencial com a finalidade de coordenar as decisões de uma empresa no alcance de suas metas, através de um valor fixado. Abrange as operações de vendas ou as transferências de produtos, serviços, estando presente em unidades descentralizadas, ou seja, companhias que optaram pela sua fragmentação organizacional, dividindo suas estrutura fixa em áreas de negócios. Neste contexto, o objetivo principal desse trabalho foi verificar a importância do apreçamento de transferência utilizado nas unidades descentralizadas de uma cooperativa agroindustrial, estudando seus procedimentos, bem como o tratamento e identificação da metodologia adotada nesse processo de venda interna nas divisões de recebimento e refino da soja. Assim, através de um estudo de caso, procurou-se identificar a participação das unidades descentralizadas no resultado da cooperativa agroindustrial do norte do Paraná, e o apreçamento de transferência interno adotado por essa organização. Portanto, conclui-se que desempenho de cada uma das unidades afeta de forma direta o resultado final da empresa, embora cada centro de responsabilidade adote um mecanismo de apreçamento condizente com suas atividades. A importância da gestão do preço de transferência otimiza esse processo de forma positiva, contudo está compactado ou muito próximo as formas de custeio, prejudicando consequentemente seu trabalho como mensurador da performance

This dissertation explores the issues of mixed oligopoly, restructuring, and M&A that occurs in turn on the stages of policy set-up, preparation, and performing when the government attempt to privatize the state-owned enterprises (SOEs). On the policy set-up stage, private firms in domestic market are not necessary confined to originate at home country. Foreign private firms may establish an oversea subsidiary and create a mixed oligopoly market structure at home country. In addition, those foreign private firms may not passively accept all the trade policies that came from the government decision of home country. Mixed oligopoly competition between one domestic public firm and one subsidiary of foreign private firm is been formulated to investigate the following questions: (1) how the agents compete under the cases that home country government adopts policies such as corporate tax rate, repatriation tax rate, and partial offering public stocks; and the foreign private firm implements strategies such as vertical integration and transfer pricing; (2) the impact on social welfare and the decision of optimal public stock-offering ratio while home country government¡¦s policies and foreign private firm¡¦s strategies have changed. New findings include (1) Home country government can not maximize social welfare by simply adopting strategic policies; (2) For home country government, the best strategy for privatizing SOEs maybe partial privatization; (3) For home country government, ¡§mass privatization¡¨ should be avoided as the means of manipulating domestic market shares. On the preparation stage, an incentive scheme model is designed to analyze the governance mechanism for improving SOEs¡¦ situation. First, different types of SOEs are classified according to their own ability and the employees¡¦ attitude for privatization. By offering a sound device of incentive scheme, the government is able to strengthen the SOEs¡¦ ability and employees¡¦ desirability. Within a one-stage symmetric information game framwork, it proves that SOEs with high ability and their employees with high privatization desirability can implement the highest amount of public stock offering ratio. Next, it utilizes a two-stage asymmetric game model for discussing how to improve the SOEs¡¦ ability and how to encourage the employees to support privatization. By providing an incentive contract, the government not only can coerce the SOEs but also can inspire their employees to reveal their true information. The due process of public stock offering is able to strengthen the abilities of SOEs via ¡§restructuring¡¨ on the one hand, and to facilitate the issue of ¡§training subsidies¡¨ for hatching the entrepreneurship of employees on the other hand. Finally, it investigates the impact on public stock offering ratio for the amount of specific grants, and found that the more generosity of incentive contract, the higher the public stock offering ratio. On the performing stage, it adopts the incentive theorem to analyze the outcome of SOEs¡¦ privatization by inviting a named firm. The named firm takes over the SOEs through M&A for the purpose of long-term operation. In order to encourage the employees of the privatized company working more aggressively, the named firm comes up incentive schemes including bonus-sharing and Employees Stock Ownership Plan, ESOP. It found that whether there exists information asymmetry or not between the named firm and the employees of the privatized company will affect the following decision-makings: the level of the employees¡¦ effort, the willingness of the employees¡¦ stock-holding, and the achievement of the named firm¡¦s profit maximizing objective. In particular, it shows that the change of the contents of the incentive schemes will affect the bargaining outcomes between the named firm and the trade union of the SOEs on the issue of working conditions after privatization.