Transfer Pricing Model Based on Multiple-Factor Transfer Pricing Model using the Transactional Net Margin Method

Abstract

Decision-making process on the optimization of transfer pricing has two dimensions that need to be considered: optimization dimension in terms of available capacity, tax laws of countries, available market and other indicators of the individual company, and dimension of transfer pricing regulation at the international level in accordance with the OECD Guidelines. Current multiple-factor transfer pricing model examines only the first dimension of transfer pricing between related parties. Transfer price method, expressed in a form of transfer pricing model using the transactional net margin method, is built in a multiple-factor transfer pricing model in order to meet the conditions of transfer prices at arm’s length principle. In this way a new transfer pricing model is formed; a model that optimizes the operations of multinational companies and is in line with the OECD Guidelines on transfer prices.