Trade and Transfer Pricing

Abstract

Although there may be difficulties, especially during challenging economic times, in applying profit-based regulations when an income tax dimension is considered, if a trade dimension is introduced, in some circumstances profit-based methods, such as the comparable profits method (CPM) or transactional net marginal method (TNMM), may be preferred transfer pricing methods for multinationals. The article provides a comprehensive overview of the profit-based methods CPM and TNMM, where advantages and disadvantages of these methods are considered, and differences between these two methods are pointed out. The article also introduces a conceptual framework for transfer price coordination in the context of income tax and customs laws and examines issues pertaining to harmonization of income tax and customs laws.