Transfer pricing (from Eng. Funds Transfer Pricing, abbr. FTP) - a mechanism for the implementation of all kinds of goods interdependent entities (usually within holdings) in particular, intra, not market prices.So perhaps a more rational and cost-effective redistribution of income in favor of a group of persons who are in a lower tax (generally, this means staying in other states).Such a scheme of tax planning is necessary to minimize the costs associated with the mandatory tax deductions.Transfer prices are controlled by the fiscal authorities of the state.
Transfer pricing in a regulated system in detail appeared in the mid-60s in the United States, then this method of pricing policy has spread to other countries of the world.In Russia since the beginning of 2012 special legislation governing transfer pricing.Until 2012, it was regulated by the Tax Code.
There are three methods by which transfer prices are determined:
- method uncontrolled (comparable) prices;
- resale price method;
- a "cost plus profit".
When using the first method set the list price.With this method, the tax authorities have the right to additional taxes and penalties, if commodity prices are above or below more than 20% of the market for similar products.
The second method is used when the sale is carried out on the eve of the transfer of goods between the parties.Thus you can reduce the resale price on the value of margins, due to which the costs are covered by the seller.
third method is used in cases where it is impossible to use the previous two.At the same time to determine the market value takes into account all direct and indirect costs of the seller, it is added to the average margin inherent in the industry.Such an approach necessarily involves drawing up the standard cost estimate for all products (services).
Generally, transfer pricing is used for two reasons:
- if you want to efficiently reallocate financial resources within the holding;
- when it is possible to minimize the additional payments, and thus to optimize taxation.However, one should mention that this "optimization" is often regarded by the state rather as an attempt to evade the conscientious fulfillment of tax obligations.On the other hand, taxpayers have every right to use such a tool to achieve more favorable economic results of its own activities.
The use of this type of pricing for large holdings and corporations is very advantageous because it allows to organize practically command structure in a market economy.So the opportunity to concentrate in a single profit center and later to redistribute it to the needs of the holding companies.Letting the redistribution of own funds of major economic actors are not rational.Probably just the regulation of this area in order to prevent budget losses.
example, transfer pricing, in its essence, is quite ambiguous phenomenon that has caused attention to it from the state.The need to improve the pricing principles, for tax purposes, July 18, 2011 was signed by the Russian law on amendments to some legislative acts.Particular attention was paid to it transfer prices.The Tax Code has been amended to Article 40, which limits the transfer price fluctuation within +/- 20% of the price, which provides market pricing.
Standards Act is fully consistent with international principles of regulation of pricing.It was based on the Guidelines for the formation of transfer prices adopted by the Committee of the Organization for Economic Cooperation and Development.
