F5知識(shí)點(diǎn)：轉(zhuǎn)讓定價(jià) （Transfer Pricing）的重要性

　　F5知識(shí)點(diǎn)：轉(zhuǎn)讓定價(jià)（Transfer Pricing）的重要性

　　轉(zhuǎn)讓定價(jià)（Transfer Pricing） 是指關(guān)聯(lián)企業(yè)之間在銷售貨物、提供勞務(wù)、轉(zhuǎn)讓無形資產(chǎn)等時(shí)制定的價(jià)格。在跨國(guó)經(jīng)濟(jì)活動(dòng)中，利用關(guān)聯(lián)企業(yè)之間的轉(zhuǎn)讓定價(jià)進(jìn)行避稅已成為一種常見的稅收逃避方法，其一般做法是：高稅國(guó)企業(yè)向其低稅國(guó)關(guān)聯(lián)企業(yè)銷售貨物、提供勞務(wù)、轉(zhuǎn)讓無形資產(chǎn)時(shí)制定低價(jià)；低稅國(guó)企業(yè)向其高稅國(guó)關(guān)聯(lián)企業(yè)銷售貨物、提供勞務(wù)、轉(zhuǎn)讓無形資產(chǎn)時(shí)制定高價(jià)。這樣，利潤(rùn)就從高稅國(guó)轉(zhuǎn)移到低稅國(guó)，從而達(dá)到限度減輕其稅負(fù)的目的。

　　Transfer price- the price at which one division transfers goods or services to another division within a company or from one subsidiary to another within a group.

　　WHY TRANSFER PRICING IS IMPORTANT

　　It is essential to understand that transfer prices are only important in so far as they encourage divisions to trade in a way that maximises profits for the company as a whole. The fact is that the effects of inter-divisional trading are wiped out on consolidation anyway. Hence, all that really matters is the total value of external sales compared to the total costs of the company. So, while getting transfer prices right is important, the actual transfer price itself doesn't matter since the selling division's sales （a credit in the company accounts） will be cancelled out by the buying division's purchases （a debit in the company accounts） and both figures will disappear altogether. All that will be left will be the profit, which is merely the external selling price less any cost incurred by both divisions in producing the goods, irrespective of which division they were incurred in.

　　As well as transfer prices needing to be set at a level that maximises company profits, they also need to be set in a way that is compliant with tax laws, allows for performance evaluation of both divisions and staff/managers, and is fair and therefore motivational. A little more detail is given on each of these points below：

　　If your company is based in more than one country and it has divisions in different countries that are trading with each other, the price that one division charges the other will affect the profit that each of those divisions makes. In turn, given that tax is based on profits, a division will pay more or less tax depending on the transfer prices that have been set. While you don't need to worry about the detail of this for the Paper F5 exam, it's such an important point that it's simply impossible not to mention it when discussing why transfer pricing is important.

　　From point 1, you can see that the transfer price set affects the profit that a division makes. In turn, the profit that a division makes is often a key figure used when assessing the performance of a division. This will certainly be the case if return on investment （ROI） or residual income （RI） is used to measure performance. Consequently, a division may, for example, be told by head office that it has to buy components from another division, even though that division charges a higher price than an external company. This will lead to lower profits and make the buying division's performance look poorer than it would otherwise be. The selling division, on the other hand, will appear to be performing better. This may lead to poor decisions being made by the company.

　　If this is the case, the manager and staff of that division are going to become unhappy. Often, their pay will be linked to the performance of the division. If divisional performance is poor because of something that the manager and staff cannot control, and they are consequently paid a smaller bonus for example, they are going to become frustrated and lack the motivation required to do the job well. This will then have a knock-on effect to the real performance of the division. As well as being seen not to do well because of the impact of high transfer prices on ROI and RI, the division really will perform less well.

　　The impact of transfer prices could be considered further but these points are sufficient for the level of understanding needed for the Paper F5 exam. Let us now go on to consider the general principles that you should understand about transfer pricing. Again, more detail could be given here and these are, to some extent, oversimplified. However, this level of detail is sufficient for the Paper F5 exam.