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An In-depth Discussion About Transfer Pricing

If you’re in business, then you’ve probably heard of the term “transfer pricing.” But what is it, exactly? And more importantly, how can you make sure that your company is doing it right? In this blog post, we’ll answer all of those questions and more.

What is transfer pricing?

In short, transfer pricing is the price that a company charges for goods or services sold to another company within the same group of companies. It’s an important tool for businesses because it allows them to accurately reflect the true market value of those goods and services. This, in turn, helps ensure that profits are fairly distributed among all of the companies involved.

Transfer pricing, or the pricing of transactions between affiliates in different tax jurisdictions—also known as intercompany pricing—presents both tax opportunities and financial reporting risks for multinational businesses.

Tax authorities place a heightened focus on transfer pricing to increase revenue, leading to a rise in transfer pricing audits and penalties imposed.

Proactively enacting transfer pricing procedures while working toward compliance can help your business avoid costly audits and lower your worldwide effective tax rate. So you can stay focused on its international growth.

 Purposes of Transfer Pricing

The main objectives why businesses do transfer pricing include:

Tax avoidance/minimization: Businesses can minimize their overall tax liability by setting fair prices for goods and services sold between related companies. This is especially helpful for companies that operate in multiple countries.

Risk management: By accurately pricing goods and services, businesses can reduce the risk of fraud or smuggling. It also allows them to better manage their financial risks by ensuring that they’re not over-or underpaying for products.

Profit allocation: When a company sells something to another company within its group, the profits from that sale are typically allocated based on how much of the product was produced by each company. This helps ensure that profits are fairly distributed among all businesses involved.

Customs Valuation: The fourth purpose of transfer pricing is customs valuation. When businesses trade goods and services with each other, the value of those items needs to be declared to customs. By setting a price for the goods and services, businesses can ensure that the correct value is declared to customs. This helps businesses avoid paying unnecessary taxes and fees.

Methods of Calculating Transfer Prices

Determining an appropriate transfer price can be difficult, as there are many factors to consider. This segment discusses the pros and cons of three methods commonly used to calculate transfer prices: cost-plus pricing, market pricing, and margin analysis.

Cost-Plus Pricing

The cost-plus pricing method is the most simplistic way to calculate a transfer price. Under this method, the company will simply add its costs of producing the good or service to the desired profit margin. This provides a straightforward metric for both companies involved in the transaction. However, there are some drawbacks to using cost-plus pricing. First, it does not consider market conditions, which can significantly impact prices. Second, it may not be feasible for companies to track their costs down to the individual product level accurately. Finally, adding a fixed percentage mark-up can lead to inefficient use of resources if production costs decrease over time.

Market Pricing

Market pricing takes into account current market conditions when calculating a transfer price. This means that the price will be based on what other companies are charging for similar products or services. There are pros and cons to using market pricing. On the plus side, this method ensures that both companies are getting a fair deal given the current market conditions. It can also help avoid disputes over prices, as both companies will have already agreed to the price before beginning negotiations. However, there is always the risk that market prices could change suddenly and unexpectedly, resulting in either company losing out on the transaction. Additionally, it cannot be easy to find accurate information about prevailing market prices.

Margin Analysis

The margin analysis method considers a company’s specific costs and profits associated with producing a good or service. Under this method, the transfer price is based on how much profit the company wishes to make on each unit sold. There are pros and cons to using margin analysis. On the plus side, this approach allows for greater flexibility than either cost-plus or market pricing. Companies can set prices as high or low as they want, provided they still make a profit on each unit sold.

Additionally, margin analysis can be used to compare different products and services to identify those with higher margins. However, there are some drawbacks to this method. First, it can be difficult to accurately track all of the relevant costs and profits associated with producing a good or service. Second, setting prices too high or too low could lead to lost sales or reduced profits. Finally, margin analysis does not consider market conditions, which can significantly impact prices.

Importance of Transfer Pricing

There are four main reasons why transfer pricing is important:

In order to ensure that profits are accurately allocated among companies, it is important to use a fair and reasonable transfer price. This price should reflect the actual value of the goods or services being transferred. If the transfer price is too low, then the company receiving the goods or services will end up with less profit than they should have. If the transfer price is too high, then the company providing the goods or services will end up with less profit than they should have.

Transfer pricing can also be used to avoid tax avoidance and evasion. By setting a fair and reasonable transfer price, companies can reduce their risk of being audited by tax authorities. Tax authorities may investigate companies if they believe that the prices being used for cross-border transactions.

Transfer pricing also encourages cross-border trade. When transfer prices are set fairly, it allows companies to transact with each other without having to worry about taxation. This can benefit both companies involved in the transaction and help promote economic efficiency.

Lastly, transfer pricing facilitates intra-company cooperation. By setting fair and reasonable transfer prices, companies can ensure that they are operating efficiently and that profits are being allocated fairly. This can help improve communication between companies and lead to better business relationships.

Transfer Pricing Risks and Solutions

All cross-border related party transactions are subject to scrutiny, whether your company has operated subsidiaries in multiple countries for years or you’re setting up your first foreign outpost. When it comes to transfer pricing, there are a number of risks businesses face. Here are five of the most common:

Risk #01: Incorrectly classifying goods and services

Solution: Use an appropriate transfer pricing method that accurately reflects the nature of the good or service being transferred.

Risk #02: Under- or over-estimating prices Solution: Make sure your prices reflect an arm’s length transaction by using comparable data sources.

Risk #03: Not considering all relevant factors Solution: Make sure you take into account all relevant facts and circumstances when setting your prices. This includes things like location, functionality, risk, and other business considerations.

Risk #04: Failing to file an appropriate transfer pricing report Solution: File the correct transfer pricing report with your tax authority. This will help ensure that you’re meeting all of your compliance obligations.

Risk #05: Using an inappropriate transfer pricing method Solution: Use a transfer pricing method that is suitable for your business and transaction type. There are a number of different methods to choose from, so make sure you select the one that best fits your needs.

By understanding these risks and implementing the corresponding solutions, businesses can avoid costly mistakes and ensure compliance with transfer pricing regulations.

Can you do transfer pricing with  companies in developing countries?

The answer to this question is a resounding yes! Transfer pricing can and should be done with companies in developing countries. There are, however, a few things to keep in mind when doing so.

One thing to consider is that the market conditions in developing countries may be different than those in more developed countries. This means that the prices used for transfer pricing purposes may need to be adjusted accordingly. Additionally, it’s important to make sure that the company you’re working with in a developing country is compliant with local laws and regulations governing transfer pricing.

If you take these things into account, transferring goods and services between related companies operating in different parts of the world can be a smooth process.


It is clear that transfer pricing is a critical component of global tax planning and corporate structuring. By accurately setting prices for goods and services traded between related parties, businesses can properly allocate profits across jurisdictional borders. While transfer pricing can be complex, the benefits of an effective plan can be significant. Businesses must exercise caution when implementing a transfer pricing strategy, as any missteps could lead to unwanted scrutiny from tax authorities. However, with careful planning and execution, businesses can use transfer pricing to minimize their tax liabilities and maximize their profitability.

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