4.7 Article

Decision framework for the analysis and selection of appropriate transfer pricing for a resilient global SME manufacturing operation - a business case

Journal

INTERNATIONAL JOURNAL OF PRODUCTION RESEARCH
Volume 49, Issue 18, Pages 5431-5448

Publisher

TAYLOR & FRANCIS LTD
DOI: 10.1080/00207543.2011.563835

Keywords

transfer price; comparable uncontrolled price; resale price; cost plus; comparable profits; profit split; decision tree; IRS; resilience; SME; sustainability

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The purposes of this article are to help prevent problems related to transfer pricing, add some clarity to an important tax issue and decrease small and medium enterprise's (SME's) exposure to double taxation and tax penalties for a global SME operation. Staying within compliance of transfer pricing rules and regulations is one of the challenges to SME's resilience. Various transfer pricing methods were applied to specific examples and an integrated decision framework for transfer price compliance and selection of appropriate transfer price methods was developed and applied to a global SME operation. This article will contribute to industry by creating a more seamless flow within the SME supply chain by avoiding problems that may arise. It will help SMEs to become more resilient to uncertainties within the server business conditions they are currently facing. Finally, this article will also help the related tax authorities by informing managers of tax regulations in the US and what is required to comply with the regulations.

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