Understanding transfer pricing and the classic calculation to avoid tax adjustments

Understanding transfer pricing and the classic calculation to avoid tax adjustments

Understanding transfer pricing and the classic calculation to avoid tax adjustments

Understanding transfer pricing and the classic calculation to avoid tax adjustments

transfer pricing issues


transfer pricing and classical calculation

Transfer pricing is a crucial issue for companies operating internationally. It is the price at which the different entities of a group exchange goods, services or intellectual property rights. The calculation of transfer prices is essential to avoid tax adjustments, as tax authorities ensure that transactions between related entities comply with arm's length principles.

What is transfer pricing?

Transfer pricing refers to commercial transactions between entities of the same group located in different tax jurisdictions. These transactions may include the sale of goods, the provision of services, the sharing of intellectual property or intra-group loans.

The classic method of calculation

To determine transfer prices, companies use various methods, including the traditional method of calculation, also known as the comparable uncontrolled price method (CUP). This method consists of establishing the transfer price based on the prices charged in similar transactions between independent companies.

The classic transfer pricing calculation involves the following steps:

  1. Step 1: Identify the parties and transactions involved - It is critical to identify the entities involved in the transaction and document all aspects of the transaction.
  2. Step 2: Comparison with similar transactions - Companies should look for similar transactions between independent companies in comparable circumstances. These transactions are used as a reference to establish the transfer price.
  3. Step 3: Selecting the Comparison Method - Different methods can be used to compare transactions, such as the comparable selling price method, the cost plus method, or the profit split method.
  4. Step 4: Select and apply the comparison method - Once the comparison method has been selected, companies should apply that method, adjusting prices as necessary.
  5. Step 5: Documentation - It is essential to document all steps of the transfer pricing calculation, including the data sources used, the comparison methods applied and the reasons for any adjustments.

Avoiding tax adjustments

To avoid tax adjustments related to transfer pricing, companies must respect the arm's length principles and rigorously document their calculations. Here are some practical tips:

  1. Understand the tax rules and requirements: The first step to avoiding a transfer pricing tax adjustment is to understand the tax rules and requirements that apply to your business. Familiarize yourself with international tax laws, as well as the guidelines and principles established by the Organization for Economic Cooperation and Development (OECD). This will help you understand the criteria you must meet for fair and equitable transfer pricing.
  2. Perform a thorough analysis: A thorough transfer pricing analysis is essential to avoid a tax audit. Assess the nature of your intra-group transactions, the goods or services exchanged, the risks assumed and the functions performed by each entity. This analysis will allow you to determine an appropriate transfer pricing method and to justify your transactions to the tax authorities.
  3. Use appropriate transfer pricing methods: There are several transfer pricing methods recognized by the OECD, such as the comparable uncontrolled price method, the cost plus method or the profit split method. Choose the most appropriate method based on the nature of your transactions and the information available. Be sure to document your choice carefully and have reliable data to support your transfer prices.
  4. Maintain accurate documentation: Accurate documentation is essential to avoid a tax audit. It should include a detailed description of your intra-group transactions, information on the transfer pricing methods used, as well as economic and financial analyses to support your choices. Be sure to update this documentation regularly and keep it for the period specified by tax law.
  5. Focus on transparency and cooperation: Transparency and cooperation with tax authorities are essential to avoid tax adjustments. If your company is faced with transfer pricing questions or investigations, respond proactively and provide all the information required. Engage in an open dialogue with the tax authorities and propose solutions to resolve any disputes.


Understanding transfer pricing and the classic calculation to avoid tax adjustments requires a thorough understanding of tax rules, accurate analysis and the use of appropriate methods.

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