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TP General Rule: should reflect the true cost to the whole company (More…
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Factors such as
A) Prices: may vary considerably from country to the country due to eco. Conditions or level of competition or exchange rates changes and so on.
B) Full cost usually accepted as it indicated the approximately real cost of supplying and normally a fair share of tax as a result.
C) Variable cost is not normally acceptable by supplying country as all profits are allocated to receiving division and the supplying country’s tax share would be lost equal to the fixed cost incurred by the supplying division.
if this price is above the external market price or the receiving division net revenue then the internal transfer will not and should not occur
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