services to each other. The practice affects not only the performance of
subsidiaries but also national tax revenues.
Transfer prices can be based on market price, cost, or determined by
negotiation. Oftentimes, however, minimizing tax liabilities is a central
factor. For example, if corporate income tax rates in Taiwan and Malaysia
are 20% and 40% respectively, a company's Taiwanese subsidiary can
overcharge its Malaysian subsidiary for goods or services transferred. If the
overcharge amount is $100,000, the profit reported in Taiwan is increased
by $100,000 and the tax paid to the Taiwanese government is increased by
$20,000. At the same time, the profit reported in Malaysia is reduced by
$100,000 and the tax paid to the Malaysian government is reduced by
$40,000. Over all, the company realizes a $20,000 tax savings.
Governments find it difficult to control transfer pricing. In 1993, Nissan
was fined $170 million by the United States for "unreasonably inflated"
transfer prices of automobiles imported from Japan. Japan retaliated by
fining Coca-Cola $150 million for "overcharging" its Japanese subsidiary
on inputs imported from the us.
One might conclude that the low tax rates employed by many developing
countries would help the governments boosting tax revenues, since
multinationals would attribute as much profits as possible to their
operations in those countries. Unfortunately in reality, this is not always the
case. The next article will examine how developing countries often find
themselves losers in the transfer pricing game.
26. ĐỊNH GIÁ CHUYỂN GIAO NỘI BỘ
Ngày nay, phần lớn các quy trình sản xuất đi qua nhiều nước. Chúng ta
có thể thấy một điện thoại di động được lắp ráp ở một nước với linh kiện
sản xuất từ nhiều nước khác. Khi một công ty sở hữu dây chuyền sản xuất
quốc tế như vậy thì sẽ xảy ra vấn đề định giá nội bộ. Đây là giá mà các chi
