Precios de transferencia

Abstract

Transfer prices are those to which one company transfer goods, intellectual property or render services to another related company or subsidiary. Because of this relation, transfer prices assigned are different from market prices invoiced in transactions with third independent parties. Companies establish arbitrary transfer prices due to the differences in taxation between countries and by competitive reasons, or because of restrictions to the monetary flow. Since the transfer prices are manipulated for other reasons than those derived from the conditions of the market, these transfer prices makes it difficult to evaluate the performance of the subsidiaries or related companies. The United States and many other countries are interested in the financial results and the part that represents the transfer prices, due to the impact on the amount of taxes to pay. The tax authorities are very conscious that, as a result of the differences in the tax structures, a corporation can obtain important gains when a subsidiary with higher corporative taxes, sells at cost to a related company where the same taxes are lower. The higher profit is obtained where the taxable rate on income is lower; a situation that is beneficial for the company and could probably results in tax evasion.