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Advanced Higher Business

Week 3

  1. Transfer Pricing

    1. Exploitation of local resources

Transfer Pricing

Exploitation of local resources

  • Ways in which MNCs exploit local resources

  • impact of exploitation on economies, organisations and stakeholders

  • Definition

  • Costs and benefits of using TP

  • Effects of TP on tax paid, profits, home countries and host countries

Transfer Pricing

Transfer of goods

  • Multinational Companies transfer goods, partly finished goods or supplies between their operations in one country to another.


  • To take full advantage of Economies of Scale, MNCs will have subsidiaries (branches) that specialise in different stage of production – therefore one subsidiary will transfer a partly finished good to another foreign subsidiary and so on until the final good is fully assembled


  • For example, BP Oil extract crude oil from the Gulf of Mexico and transfer it to the BP Refinery in Indiana who refine it into fuel


Transfer pricing

  • Transfer Pricing is a technique used by MNCs when declaring profit to reduce the amount of tax they have to pay.

  • A multinational will declare low profits in a country with high tax rates or high profits in a country with low tax

  • As the transfer of goods is internal, the price is set by the business themselves and is not influenced by external market forces. E.g. competition, economy, etc



Main aims of TP

  • Help achieve the company’s strategies/targets

    • Minimise overall tax liability


Profits and tax

  • The MNC will look to declare most of its profits in a country with low taxes


  • This means the business must shift profit around in order to reduce the amount of tax paid – it can do this by carefully setting transfer prices between subsidiaries


Transfer prices high and low

  • Setting a high TP when transferring to subsidiaries in high tax countries achieves the following:


  • Lowering the profit margin of the receiving subsidiary

    • Therefore lowering the profit margin overall

    • Therefore lowering the amount of tax that subsidiary has to pay


  • Setting a low TP when transferring to subsidiaries in low tax countries achieves the following:


  • Increasing the profit margin of the receiving subsidiary

    • Therefore increasing the profit margin

    • But, despite also increasing the tax, this is still less than the tax paid in the high tax country so overall tax payable is minimised


Impact of TP on MNC

Positive

  • Can reduce the amount of tax paid

    • Can increase profit margins – higher dividends for shareholders/used for finding expansion, etc

  • Can allow a legal agreement with host country to pay less tax in return for setting up operations in the country

    • Government protection from high tax bills

  • Can reduce the impact of exchange rate changes

  • Can be used to offset cost of import/export tariffs


Impact of TP on MNCs- negative

  • Potential damage to reputation if host country or consumers protest against it

- Could lead to boycotts – loss of sales & damages profits

- Lead to legal problems if host country pursue unpaid tax

  • Transfer prices have to be very carefully set to avoid investigation by tax offices

-Requires regular time-consuming internal audits

  • Masks actual regional performance

- Internal conflicts may occur between regional managers


Impact of TP on MNCs- positive

Can reduce the amount of tax paid

Can reduce the impact of exchange rate changes

Can allow a legal agreement with host country to pay less tax in return for setting up operations in the country

Can be used to offset cost of import/export tariffs


Impact of TP on MNCs- negative


Potential damage to reputation if host country or consumers protest against it (boycotts or legal problems)

Transfer prices have to be very carefully set to avoid investigation by tax offices


Impact of MNC on host countries- pos

  • Low tax countries can attract multinationals to operate in that country

    • Creates employment

    • Increases wealth

    • Boosts economy

  • Can allow maximum tax revenue to be collected by certain governments

    • Helps investment in state services and infrastructure


Impact of MNC on host countries- negative

  • Limits or reduces the amount of tax revenue taking in

    • Government spends less on country

  • Governments allowing excessive transfer pricing may look weak to voters



Impact of TP on host country positive

Low tax countries can attract multinationals to operate in that country

Can allow maximum tax revenue to be collected by certain governments


Impact of TP on host country negative

Limits or reduces the amount of tax revenue taking in

Governments allowing excessive transfer pricing may look weak to voters


Impact of TP on home country- positive

MNCs can reinvest more in growth, R&D or innovation due to having reduced tax liabilities, this will benefit the home countries economy


- Headquarters often still remain in the home counry meaning high demand for high skilled jobs- sustains employment rate

Impact of TP on home country- negative

  • Profits being declared in lower tax countries means home counry may collect less corporation tax- impacting funding of state services

  • Governments must invest in the monitoring of TP- increased costs,

Impact of TP on home country- positive

MNCs can reinvest more in growth, R&D or innovation due to having reduced tax liabilities

Headquarters often still remain in the home counry meaning high demand for highly skilled jobs


Impact of TP on home country- positive

home country may collect less corporation tax-

Governments must invest in the monitoring of TP


Explore the effects of Transfer Pricing on a multinational and its hosts countries (4) 2017 Q8a



Discuss the use of TP by a MNC (6) 2023 Q10a

  • Can reduce the amount of taxation paid by the organisation

  • Means there is more profit available for retaining

  • Leading to higher dividends for shareholders

  • Declaring profits in a country leads to taxation revenue

  • This can be used to improve state services

  • May improve organisations relationship with the government

  • The transfer price should be determined using an ‘arm-length’ principle to reduce the risk of tax offices investigating

- organisations should carry out regular internal audits to review their transfer price practices

Exploitation of local resources

  • MNCs can bring many benefits to host nations

    • Employment

    • Wealth

    • Technological advances

    • Infrastructure


  • However, they are often accused of exploiting the natural resources of a host country

    • Especially in developing nations such as various African countries


Examples of exploitation

  • Overconsumption of Natural Resources (Overharvesting)

    • Over-fishing

    • Excessive farming

    • Deep Fossil fuel drilling and mining (Fracking)

    • Overuse of water supply

    • Excessive logging (De-forestation)


  • Can result in:

    • Massive depletion of natural resources

    • Irreversible damage to farm land and natural habitats i.e. pollution, etc

    • Contributing to climate change

    • Endangerment of local species

    • Natural resource not being available to local population



Examples of exploitation

  • Financial

    • Repatriation (moving) of profits to home nation

    • Transfer pricing to lower tax obligations

    • Use of influence to lower costs – land, labour, production

    • Sale of natural resources to foreign nations


  • Can result in:

    • Local governments not collecting tax revenue

    • Use of sweatshops and/or extremely low wages and long hours

    • Host country not benefitting from its own resources

    • Damage to local competition and economy


Examples of exploitation

  • Legislation

    • Influencing government policies and taxes

    • Lower standard of Health & Safety

    • Lower standard of employee rights

    • Use of influence to threaten government


  • Can result in:

    • Government being forced to change policy or lower tax

    • Dangerous working practices

    • Poor standard of living

    • Unregulated pollution, greenhouse gases, destruction of land/sea



Q10b 2023

Impact of TP on MNCs- positive


Impact of TP on MNCs- negative



Impact of TP on host country positive


Impact of TP on host country negative


Impact of TP on home country- positive


Impact of TP on home country- positive