The transfer pricing: The full-fledged manufacturer case study

The transfer pricing is now not only a topic for multinational companies, but also for every company cooperating in multi-companies networks. The activity of tax administrators in the tax audit focused on transfer prices is increasing, and this issue becomes an almost standard part of a regular tax audit focused on corporate income tax. This paper deals with the issue of transfer pricing in a company evaluated as a full-fledge manufacturer, that is, a part of a multinational company. The concerned company is currently working to improve the quality of transfer pricing documentation. The purpose of this article is to demonstrate, in a brief case study, the basic procedure used to evaluate the differences between prices for independent companies and for associated companies. The evaluated transactions are compared with the data available from companies operating in the same industry. It was found that the profitability of the company is comparable to the expected profitability based on the calculated market profit range. According to the risk analysis, the main risks to the company resulting from the market environment and the poorly established transfer pricing policy.