Transfer Price Agreement Example

Transfer Price Agreement Example: Understanding the Basics

If you`re involved in international business, you`ve probably heard of the term “transfer pricing.” It refers to the price at which goods or services are transferred between related companies, such as different subsidiaries of the same multinational corporation. Transfer pricing has a significant impact on tax liabilities, as different countries have different tax rates and regulations. To ensure compliance with tax laws and avoid disputes with tax authorities, companies need to establish transfer price agreements. In this article, we`ll provide a transfer price agreement example and explain the key elements of such agreements.

Overview of Transfer Pricing

Transfer pricing is a challenging issue for multinational corporations, as it involves balancing economic efficiency, legal compliance, and business strategy. Companies need to consider various factors when setting transfer prices for intra-group transactions. For example, they need to take into account the value of the product or service, the market conditions, and the location of the parties involved. A transfer price that is too high or too low can result in tax penalties, audit assessments, or reputational damage.

To mitigate these risks, transfer pricing regulations require companies to establish transfer price agreements. Such agreements specify the terms and conditions of intra-group transactions, including the transfer prices and the methods used to determine them. Transfer price agreements are typically negotiated between the parties involved, but they may also be subject to review and approval by tax authorities.

Transfer Price Agreement Example

Let`s take a simple transfer price agreement example to illustrate the concept. Suppose that Company A, which is based in Country X, has a subsidiary called Company B, which operates in Country Y. Company A sells a product to Company B for $100, which Company B then sells to a third-party customer for $150. The transfer price agreement between Company A and Company B specifies that the transfer price for this transaction is based on the cost plus method, which means that Company B pays Company A the cost of production plus a markup of 20%.

The cost of production for this product is $80, which includes direct costs such as materials, labor, and overhead. Therefore, the transfer price for this transaction is $96 (i.e., $80 + $16 markup). This transfer price is deemed to be arm`s length, which means that it reflects the price that unrelated parties would have agreed upon under similar circumstances. If the transfer price were significantly higher or lower than $96, it could trigger tax adjustments or penalties.

Key Elements of Transfer Price Agreements

Transfer price agreements typically include the following elements:

1. Description of the parties involved, including their relationship and the nature of the transaction.

2. Methodology used to determine the transfer price, such as the cost plus method, the resale price method, or the profit split method.

3. Criteria for selecting the most appropriate transfer pricing method, such as the availability of reliable comparables, the nature of the product or service, and the level of risk involved.

4. Documentation requirements, such as the need to maintain contemporaneous records of transfer pricing analyses, including financial data, market research, and other relevant information.

5. Dispute resolution mechanisms, such as the use of arbitration, mutual agreement procedures, or advance pricing agreements.


Transfer pricing is a complex issue that requires careful consideration and planning. Transfer price agreements can help companies mitigate the risks of non-compliance with tax laws and avoid disputes with tax authorities. By following established transfer pricing methodologies and documenting their transfer pricing analyses, companies can ensure that their intra-group transactions are conducted at arm`s length prices. This transfer price agreement example should provide a basic understanding of how transfer pricing works and why it`s important for international business.

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