Transfer pricing as a company management tool

Abstract

This article studies one of the most complicated and yet popular company management tools, the transfer pricing. The author considers the aims and purpose of transfer pricing, the formation of a transfer pricing system as a company management tool, popular viewpoints on transfer price calculation methodologies, strengths and weaknesses of the existing approaches, and offers a hypothesis on transforming transfer pricing methods. The paper systematizes transfer pricing methods with due regard to the experience of domestic and foreign companies, the development of the Russian Federation legislation, the recommendations of the OECD, and the studies of auditing and consulting companies. The author presents an overview of the most popular transfer pricing methods which serve as a basis for using one or another method, identifies the factors of efficient management mechanism. The article analyses the specific features of using a particular management mechanism in financial companies and companies operating in real economy, studies the methodology to deploy transfer pricing in a legal entity and within a vertically integrated holding. Taking into account the fact that regulation of transfer pricing is also a tax regulation tool used by the state, the author emphasizes that the problems of transfer pricing tools aimed at tax risk management are not the object of the article. The results of the study can be used by employees and executives of corporate financial divisions, analysts, consultants, and employees of state agencies and authorities while developing the methodology for using financial instruments in company management.