Transfer pricing

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In cost and performance accounting , the transfer price (also known as transfer price or group transfer price ) is the price that is charged between different areas of a company or between different companies in a group for goods and services exchanged within the company (e.g. deliveries of goods, licenses, loans) .

The peculiarity of transfer pricing is that they are not formed in a market through the interplay of forces between supply and demand. Transfer prices gain economic importance in two respects:

Transfer pricing functions

Steering and coordination

Transfer pricing can be used to influence the behavior of the individual divisional managers in such a way that the profit of the entire company is maximized. Just like the economy pretial, i.e. H. is coordinated via the price, the resources can also be optimally used in the company via coordinating "steering prices". With this “ pretial steering ”, the plans of the divisional managers relate to the price at which a transfer is assessed.

In this way, the company management can withdraw from the operational management and deal with strategic issues, since certain decisions of the areas can be made autonomously via transfer prices. However, this greater degree of personal responsibility in the areas in decentralized organizational structures can lead to area egoism, which in turn can have suboptimal effects from a company perspective.

The steering function of the transfer pricing is considered fulfilled if the decisions of the divisional managers on the basis of the transfer pricing correspond exactly to the decisions that an - omniscient - head office would have made.

Success attribution and motivation

By evaluating internal transfers, the success evaluation of the areas takes place indirectly through the transfer prices. On the one hand, it is the (internal) revenue of the supplying or performing area; on the other hand, it indicates the (internal) cost of the purchasing area. This division success is the basis for decisions by division management; the management of the company ties in strategic measures or allocations of funds and it is used to assess performance. The problem with the determination of success is the offsetting of synergies (e.g. economies of scope ) - these are usually not assigned to any of the areas involved, as they only arise from the joint performance.

Transfer pricing can influence certain parameters that are relevant for the motivation of decision-makers. However, they themselves do not have a direct motivational effect. So that a transfer pricing system can trigger an extrinsic motivational effect, a connection must be established between the departmental decisions on the basis of the transfer pricing used, the profit and loss accounts of the departments and the assessment of the department heads responsible. For a motivational effect, however, the division manager must also have the opportunity to influence the success and accept the transfer pricing system. Then targeted rewards can be used and the division manager will try to optimize his assessment size accordingly. However, if factors that cannot be influenced lead to financial losses for the division manager, this can also have a negative motivational effect. By means of transfer prices and the simulation of a market, divisional managers can be put into the role of “ quasi-entrepreneurs ”, whereby the need for self-realization is satisfied and performance can be stimulated.

Tax minimization

In a group , profits can be shifted between several legally independent companies in a group of companies via transfer prices: The profit can be shifted to the supplying or purchasing company by setting transfer prices. If the two areas are of different legal form or if the head office is in areas with different tax burdens, the transfer price will be chosen so that the greatest profit is generated by the company with the lowest tax burden. However, there are limits to this due to national and international tax regulations. In the course of the abolition of interstate trade barriers, taxation differences have an increased influence on business decisions. If the tax authorities involved make different corrections, there is also the risk of double taxation . The economic importance of the tax minimization function becomes clear when one considers that, according to estimates by the OECD, more than 60% of world trade is carried out through intra-group transactions. This has brought transfer pricing into the focus of the tax legislator's interest in multinational companies. More than forty countries have recently expanded their regulations in this regard.

More functions

The following functions are also mentioned in the literature:

  • Simplification and acceleration: By decoupling fluctuations in the market price , transfer prices enable differentiated analysis of deviations and cost control , for example at cost center level, by eliminating overlapping price and quantity effects .
  • Transfer prices are used in the balance sheet to evaluate the services, and thus serve to determine the balance sheet or tax-related profit or inventory valuation. Therefore, they must comply with commercial and tax regulations - discretionary leeway can be used in favor of the company. In the group, transfer pricing should also mean that the balance sheets of the group companies show certain structures and relationships, which ultimately influences the cost of capital . The interests of the shareholders and non-group creditors of the group companies must also be taken into account.
  • In the context of tenders for public contracts or in regulatory procedures for special markets, such as postal , telecommunications and energy markets , transfer prices are often used to justify the price of a service required on the (regulated) market to regulatory authorities, because in addition to the external services used, there are also to be assessed or assessed internally.

Conflicting goals

Transfer pricing can therefore fulfill a number of functions. However, it should be noted that the various functions are often in competition with one another. If a transfer price fulfills a function particularly well, it may be that another function suffers or is counterproductive. In particular, the functions of coordination on the one hand and determination of success / motivation on the other are in conflict with one another. The situation is similar between the economically motivated functions of motivation / control and the tax minimization function. The conflict of objectives becomes clear when, for example, international transfer prices are designed purely for considerations of tax minimization. By disregarding the coordination function in the formation of the transfer price, distorted management decisions are made, which in turn can negatively affect the overall result. The conflicting goals become clear when analyzing different types of transfer pricing.

Types of transfer pricing

The procedure for determining transfer prices is often not fully understood or accepted in practice in terms of its significance for the informative value of the invoice and for the aspect of influencing behavior. In the following, the various options for setting transfer prices are to be examined. It is initially assumed that the head office will set the transfer prices so that the functions it is striving for are fulfilled as well as possible.

Market price-oriented transfer prices

Actual market prices

One way of setting transfer prices is to use a market price. The aim is to simulate a market in order to let market mechanisms take effect. The market price is an indicator of efficiency.

In order for this transfer to succeed, however, a perfect market must prevail:

  1. Both areas have access to the market.
  2. There is a market with a uniform market price for a service that can fully substitute the internal service .
  3. The market capacities are unlimited in terms of both sales and procurement .
  4. The transfer price must take into account mathematically ascertainable synergy advantages that do not apply to external services or purchases. Beyond that, there are no synergy advantages that cannot be calculated mathematically (such as poor quality , unsafe delivery, risk of losing secrets, etc.).
  5. The transfer price must be adjusted to fluctuations in market prices.

If a market price fulfills these conditions, this would have the advantage that both the profit of the company as a whole is maximized (coordination function) and the partial successes can be viewed as generated by the respective area. Market-oriented transfer prices are therefore well suited for determining success. Further advantages are the low manipulability due to its objectivity and the recognition by tax authorities (see so-called dealing at arm's length principle) and the other corporate areas. Correspondingly, the application of a market-oriented transfer price in perfect markets only leads to a need for coordination through the overall goal-optimized coordination if there are synergy effects between the areas.

If the above conditions do not apply, i.e. a perfect market does not exist, the coordination function is not optimally fulfilled. Market-oriented transfer prices, for example under internal and external purchase or sales restrictions, lead to a coordination that is not optimal as a whole. If the supplying department cannot deliver to the market at a relatively high market price (which is used as a transfer price), it is not worthwhile for the supplying department to produce due to the high purchase price; the supplying area has no buyer. Using the market price means that the overall optimum is not met.

It turns out that market prices as transfer prices only optimally fulfill the coordination function if there is a perfect market. However, market prices should definitely be taken into account when determining optimal transfer prices, as these always have the character of opportunity costs and indicate what result could have been achieved with an external transfer.

It must be noted that it is sometimes difficult to identify objective market prices, especially for company-specific internal services. This problem can be circumvented by not only looking for market prices that exist for substitution services , but also by using any existing comparable services as a starting point.

Modified market prices

In order to nevertheless fulfill the steering function in the presence of an imperfect market, the market prices can e.g. B. be modified so that the transfer price is determined as the market price minus the additional sales costs incurred for internal services. This is intended to equate internal and external transfer alternatives. At the same time, this means that the entire benefit from internal instead of external delivery accrues to the purchasing department. Under certain circumstances, this can be useful if it is intended to reduce the (internal) market power of the supplying area. For the determination of success, however, modifications usually mean a certain arbitrariness for the distribution of the total profit to the affected areas.

Cost-oriented transfer pricing

Marginal cost

If it is a matter of coordinating the amount of internal transfer and optimizing it from the point of view of the company as a whole, it can be formally shown that only marginal costs , understood as relevant costs for short-term decisions, solve this coordination problem. However, they only do this under certain conditions with regard to the information situation of the head office and the areas and thus only seemingly. This assessment is reinforced by the low level of use in practice.

According to Coenenberg, marginal costs can be used as the transfer price if the following requirements are met:

  1. Services cannot be sold on the external market, or only to a limited extent.
  2. There are no employment bottlenecks in the performing area.

Under these conditions it is assumed that a company produces x pieces of end product which are sold on the sales market at a price p (x) with p '(x) <0. A piece of the end product requires exactly one unit of the service provided by the producing area. The cost functions of the supplying and producing areas are convex. The company's profit is: G (x) = p (x) * x - K 1 (x) - K 2 (x). The supplying range maximizes G 1 (x) = v * x - K 1 (x), the receiving range maximizes G 2 (x) = p (x) * x - v * x - K 2 (x), where v denotes Transfer pricing symbolizes. If the marginal costs of the supplying area are set as the transfer price for the centrally optimal quantity x *, v = K 1 '(x *), both areas determine the same optimal production quantity x' in a decentralized manner. However, this only appears to solve the steering problem. The central office has to know the optimal amount x 'and for this it has to solve the problem in advance. The head office could “just as easily prescribe the output volume” to the areas.

By using marginal costs, a real basis for decision-making is created in the customer area. However, marginal costs in the performing area always lead to a loss in the amount of the fixed costs . In contrast, a profit is assigned to the purchasing department, which was only partially achieved through its own work.

With limited availability of in-house services, there is competition between the various possible uses. In this situation, scarcity prices are used as transfer prices. The scarcity price of a good corresponds to the marginal costs plus the marginal opportunity costs (= congestion-related contribution margin ). In the case of scarce prices, the performance-related allocation of profit cannot be resolved. In addition, if there are several bottlenecks, the calculation of the scarcity prices requires the planning problem to be solved.

Full costs

The basic idea of ​​transfer pricing in the amount of full costs is to cover the entire costs of the performing area (on average) . Coenenberg states that the main advantage is that with this method the customer looks as if he had created the service himself. The performing area is no longer “damned” as in the approach of marginal costs for generating a loss. However, the area cannot generate a profit, so this method is only suitable for functionally organized [cost centers].

Full costs are not very suitable as a basis for decisions. They include costs that are not relevant for the decision, they fluctuate depending on the level of employment and the allocation is to a certain extent arbitrary due to the necessary coding of the overhead costs for different services. This could not be accepted by the decreasing areas as causal. Full costs can therefore only serve as an approximation of the long-term variable costs. Another problem is that prices calculated on the basis of full costs become variable costs for the purchasing department - if he asks one less unit, the purchase costs are reduced by exactly the transfer price. In decision-making situations based on variable costs, this can lead to wrong decisions.

Dual transfer pricing

Dual transfer prices make use of the possibility of varying internal prices: Why does the same transfer price have to apply to the supplying and purchasing areas? Dual transfer prices set different transfer prices for the areas. The center fulfills a balancing function across the different areas. For example, the supplying area can receive the market price, while the customer department only pays the variable costs for the internally transferred service. As a result, the purchasing department subsequently makes decisions based on the marginal costs, while the performing department can still achieve a division success. With this method, however, the total profit of the company is lower than the sum of the divisional profits, which means that a ranking of the companies is not possible and the success determination function is not fulfilled. This inevitable consequence is one of the main reasons why dual transfer prices hardly meet with acceptance in practice. Acceptance suffers from the fact that the question of which of the two prices is the "right" one will arise again and again, which can always only be answered unsatisfactorily.

Negotiated transfer prices

In the case of negotiated transfer prices, the central office does not set the transfer prices, but rather they represent the result of negotiations between the areas. The advantage of this approach is that the individual areas have better information about the cost and revenue situation. Negotiated transfer prices are based on the idea of ​​creating a solution that approximates the market price. An exchange of information takes place in the negotiations . Negotiations can also be time-consuming or lead to conflicts. If a trade takes place, the success is divided between the areas according to the bargaining power , which means that negotiating skills in transfer pricing are rewarded. As a result, the head office does not make specific adjustments in its favor. Ultimately, however, general statements about the efficiency of negotiated transfer prices are not possible.

Tax-motivated transfer pricing

The steadily growing importance of the tax aspect is fed by the trend of the last decades that the cross - border internal exchange of services is increasing rapidly in volume. In the case of internal transactions that are carried out across national borders, the choice of transfer price has, on the one hand, significant fiscal effects for the countries involved. On the other hand, with different tax rates in the participating states, there is the possibility of shifting corporate profits to low-tax countries (tax arbitrage). In response to this development has been - by the OECD promoted - at the international level of the arm's length principle (arm's length principle) enforced. According to this, companies are obliged for tax purposes to choose a transfer price for cross-border in-house services that external third parties (i.e. completely independent companies) would have agreed on for the same transaction. The determination of such an arm's length price is generally difficult due to the lack of comparable transactions and is therefore based in practice on established methods that are explained in the transfer pricing principles of the OECD and accepted by the German tax authorities. The tax documentation requirements with regard to transfer pricing have been tightened significantly in most industrialized countries in recent years. Bittner / Heidecke (2013) provide an overview of the tax perspective on transfer pricing including an illustration of the methods. The manuals by Wassermeyer (2014) and Vögele / Borstell / Engler (2011) allow a more in-depth treatment of the topic, including special topics such as license offsetting or the relocation of functions with a legal focus. Renz / Wilmanns (2013) have prepared the topic in their standard work, especially for practitioners.

Profit neutrality of transfer pricing in domestic transactions

Since the same tax rate applies to all transactions within one and the same country and affiliated companies have the same owner, there is no economic indication of which transfer price a company should choose. In addition, according to the rules of group accounting, any intercompany profit or loss must be eliminated again for the annual financial statements. A simple example should illustrate this statement.

Let us assume that a corporation produces consumer goods that can be sold to end customers for 100 euros. The group consists of two individual companies: a production company and a sales company, both of which are located in Germany. The material used to manufacture the products is 50 euros per piece and there are no additional costs (especially no overheads). The sales company incurs sales costs of 20 euros for each item to be sold. Corporate profits are taxed at 30%. Let us now consider net profit in the following two scenarios. It should be noted that the sales price of the production company corresponds exactly to the purchase price ( cost of materials ) of the sales company:

A) The group chooses VP = 50 as the transfer price (VP) between the two companies
Manufacturing company Sales company
sales 50 (VP) 100 (final price)
Cost of materials 50 50 (VP)
Gross profit 0 50
Selling / administrative costs 0 20th
Operating profit 0 30th
tax 0 (30%) 9 (30%)
Net income after taxes 0 21st
B) The group chooses VP = 80 as the transfer price between the two companies
Manufacturing company Sales company
sales 80 (VP) 100 (final price)
Cost of materials 50 80 (VP)
Gross profit 30th 20th
Selling / administrative costs 0 20th
Operating profit 30th 0
tax 9 (30%) 0 (30%)
Net income after taxes 21st 0

Effects on tax revenue and net profit in international transactions

In international transactions, the choice of transfer price has an impact on the tax revenues of the countries involved and, in the case of tax rate differentials between the two countries, on the group profit.

Let us continue with the introductory example and initially assume that the production company remains in Germany, while the sales company is now in another country with the same tax rate of 30%. Then nothing changes in the final consolidated profit, but in scenario A the tax income for Germany is zero, while in scenario B it amounts to nine euros. With tax rate differentials, there is an incentive for the companies involved to minimize the group tax rate through a clever choice of the transfer price. Let's stay with the example: If the taxes in the country of the sales company are only 20%, the following picture emerges:

A) The group chooses VP = 50 as the transfer price (VP) between the two companies
Manufacturing company Sales company
sales 50 (VP) 100 (final price)
Cost of materials 50 50 (VP)
Gross profit 0 50
Selling / administrative costs 0 20th
Operating profit 0 30th
tax 0 ( 30% ) 6 ( 20% )
Net income after taxes 0 24
B) The group chooses VP = 80 as the transfer price between the two companies
Manufacturing company Sales company
sales 80 (VP) 100 (final price)
Cost of materials 50 80 (VP)
Gross profit 30th 20th
Selling / administrative costs 0 20th
Operating profit 30th 0
tax 9 ( 30% ) 0 ( 20% )
Net income after taxes 21st 0

By choosing the transfer price, the group's after-tax profit can be influenced (group profit of 21 versus a group profit of 24).

The arm's length principle

Transfer prices in cross-border transactions have the character that at least three parties regularly appear at the same time: the multinational corporation and the financial administrations of the two countries involved. This means that the selected transfer price must be accepted by the tax authorities in both countries in order to avoid the threat of double taxation for the company involved. As international regime for such interstate acceptable transfer price has the arm's length principle ( 'arm's length principle') established. This states that corporations must structure their transfer prices as if the underlying transaction were not taking place between companies of the same group but between independent market participants. The OECD defines the principle in its 'Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations' as follows:

The arm's length principle requires that compensation for any intercompany
transaction shall conform to the level that would have applied had the
transaction taken place between unrelated (third) parties under similar conditions

However, it should be noted that the is no arm's length price. As a rule, in practice the maximum range that can be determined for the price that can be viewed as arm's length.

Methods for determining arm's length prices

As standard methods , the comparable uncontrolled price method, the resale method and the cost plus method are called.

The business transaction-related (business transaction-related net margin method, business transaction-related profit sharing method) and the global methods (global comparison of operations , global profit sharing) are referred to as supplementary methods .

  • Price comparison method: With the price comparison method (CUP, comparable uncontrolled price method), prices are used that are agreed from comparable transactions between (external price comparison) or with (internal price comparison) third parties.
  • External price comparison
The transactions that would have been agreed between two completely independent third parties are used as a benchmark. A comparable, i.e. H. an almost identical performance, this third party can be considered. If the performance to be assessed is not a so-called world market product (e.g. oil or coffee), this is extremely difficult.
  • Inner price comparison
The transactions that the (group) company conducts with external third parties are used as a benchmark. These are then compared with the business of the (group) company and a person closely related to it.
On the whole, the price comparison method is rarely used in practice because it is precisely in line with the nature of affiliated companies to maintain exchange relationships exclusively within their own group and not to conduct any transactions with third parties.
  • Resale price method
With the resale price method (RPM), the transfer price is determined as follows: A customary gross profit margin is deducted from the resale price, which takes into account the functions performed by the reselling unit. (Retrograde determination).
  • Add-on method
With the cost plus method, the transfer price is determined on the basis of the costs of the related company determined on a business basis, taking into account an appropriate gross margin achieved by companies that are comparable in terms of the functions performed and the risks assumed.
  • Transaction Net Margin Method (TNMM)
With the transaction-related net margin method (TNMM, transactional net margin method), the net margins agreed between the related parties for the delivery or service are compared with the agreed net margins of external companies with the same risk and functional structure.
  • Profit sharing method
With the profit split method, the profit is divided between the related parties using a distribution key.

Tax documentation requirements

Most industrialized countries around the world now have legal documentation requirements for transfer pricing for tax purposes.

In Germany, the documentation obligations of companies are set out in Section 90 Paragraph 3 of the Tax Code (obligation to cooperate in matters abroad), the scope and structure of which in the interest of uniform application of the law by the "Ordinance on the type, content and scope of records within the meaning of Section 90 Paragraph 3 of the Tax Code ”(Profit Accrual Recording Ordinance - GAufzV). In addition, the Federal Ministry of Finance has published some administrative principles that bind the work of the financial administration. In particular, the so-called procedural principles procedures should be mentioned: the administrative principles-cost allocation and the administrative principles-posting of employees. In addition, the Federal Ministry of Finance has published information sheets on mutual agreement and arbitration procedures as well as advance pricing agreements .

Web links

Individual evidence

  1. ↑ cf. Theurl / Meyer, Verrechnungspreise 2004, p. 167.
  2. ↑ This model and the term “driving prices” go back to Eugen Schmalenbach , cf. Schmalenbach, Eugen: About transfer pricing. In: Zeitschrift für Handelswissenschaftlicheforschung (3) 1908/1909, pp. 165-184, quoted from: Trost, Verrechnungspreise 1998, p. 51.
  3. ↑ cf. Friedl, Controlling 2003, pp. 447f.
  4. ↑ cf. Theurl / Meyer, Verrechnungspreise 2004, p. 167.
  5. ↑ cf. Ewert / Wagenhofer, company accounting 2005, p. 579f.
  6. ↑ cf. Ewert / Wagenhofer, company accounting 2005, p. 580.
  7. ↑ cf. Kreuter, Verrechnungspreise 1999, p. 143.
  8. ↑ cf. Scholz, Group transfer pricing 1999, p. 28.
  9. ↑ cf. Kreuter, Verrechnungspreise 1999, p. 157 f.
  10. ↑ cf. Bruckschen, Verrechnungspreise 1981, p. 87.
  11. ↑ cf. Kleinschnittger, Beteiligungs-Controlling 1993, p. 122.
  12. ↑ cf. Scholz, Group transfer pricing 1999, p. 52.
  13. ↑ cf. Kahle, transfer pricing 2007, p. 96.
  14. ↑ cf. Kahle, transfer pricing 2007, p. 96.
  15. ↑ Transfer Pricing  ( page no longer available , search in web archives )  Info: The link was automatically marked as defective. Please check the link according to the instructions and then remove this notice. Vecteurs de croissance n ° 1 (version PDF), p. 10.@1@ 2Template: Dead Link / www.cc.lu  
  16. ↑ cf. Trost, transfer pricing 1998, p. 50.
  17. ↑ cf. Mensch, transfer pricing 2003, p. 926.
  18. ↑ cf. Kilger, Tasks 1984, p. 4.
  19. ↑ cf. Kleinschnittger, Beteiligungs-Controlling 1993, p. 122.
  20. ↑ cf. Weber / Schäffer, Controlling 2006, p. 200.
  21. ↑ cf. Mensch, transfer pricing 2003, p. 926.
  22. ↑ cf. Ewert / Wagenhofer, Unternehmensrechnung 2003, p. 600.
  23. ↑ cf. Stoffels / Kleindienst, transfer pricing 2005, p. 94f.
  24. ↑ cf. Schuster / Mähler, transfer pricing 2002, p. 600.
  25. ↑ cf. Küpper, Controlling 2005, p. 396.
  26. ↑ cf. Mensch, transfer pricing 2003, p. 927.
  27. ↑ cf. Coenenberg, Kostenrechnung 2007, pp. 687ff; here it is shown in detail why these requirements are indispensable
  28. ↑ The coordination function is essentially fulfilled because the areas are indifferent between internal and external delivery or reference and their decisions thus correspond to those of an omniscient center; Friedl, Controlling 2003, pp. 447f.
  29. ↑ cf. Wala, transfer pricing problematics 2007, p. 469; Coenenberg, Kostenrechnung 2007, p. 688.
  30. ↑ cf. Küpper, Controlling 2005, p. 401.
  31. ↑ cf. Coenenberg, Kostenrechnung 2007, p. 688.
  32. ↑ cf. Kahle, transfer pricing 2007, p. 97.
  33. ↑ This term, which originates from American tax law and can be translated as “comparison between third parties” and “third party comparison”, means that the performance fee between independent group companies is to be set as if they were unrelated, i.e. independent market participants; Scholz, Group transfer pricing 1999, p. 63.
  34. ↑ cf. Scherz, Verrechnungspreise 1998, p. 136.
  35. ↑ cf. Ewert / Wagenhofer, company accounting 2005, p. 589.
  36. ↑ cf. Küpper, Controlling 2005, p. 401.
  37. ↑ cf. Ewert / Wagenhofer, Unternehmensrechnung 2005, p. 592ff.
  38. ↑ cf. Coenenberg, Kostenrechnung 2007, p. 689.
  39. ↑ cf. Küpper, Controlling 2005, p. 401.
  40. ↑ cf. Scherz, Verrechnungspreise 1998, p. 135.
  41. ↑ cf. Trost, transfer pricing 1998, p. 60.
  42. ↑ cf. Wagenhofer, Verrechnungspreise 2002, p. 2077.
  43. ↑ cf. Ewert / Wagenhofer, Corporate Accounts 2005, p. 598.
  44. ↑ cf. Coenenberg, cost accounting 2007, p. 705.
  45. ↑ The price therefore falls as the sales volume increases
  46. ↑ So they have a minimum
  47. ↑ suction. Hirshleifer model; Wagenhofer, Verrechnungspreise 2002, pp. 2077f; for details see Ewert / Wagenhofer, Unternehmensrechnung 2005, p. 598.
  48. ↑ cf. Ewert / Wagenhofer, company accounting 2005, p. 600.
  49. ↑ cf. Weber / Schäffer, Controlling 2006, p. 202.
  50. ↑ cf. Horváth, Controlling 2001, p. 594.
  51. ↑ cf. Coenenberg, cost accounting 2007, p. 703.
  52. ↑ Ewert / Wagenhofer, Unternehmensrechnung 2005, p. 603.
  53. ↑ cf. Coenenberg, Kostenrechnung 2007, pp. 703f.
  54. ↑ cf. Theurl / Meyer, Verrechnungspreise 2004, p. 171.
  55. ↑ cf. Ossadnik, Controlling 1998, p. 234.
  56. ↑ cf. Wagenhofer, Verrechnungspreise 2002, p. 2078.
  57. ↑ cf. Ewert / Wagenhofer, company accounting 2005, p. 606.
  58. ↑ cf. Ewert / Wagenhofer, company accounting 2005, p. 615.
  59. ↑ cf. Wala, transfer pricing problematics 2007, p. 473.
  60. ↑ cf. Friedl, Controlling 2003, p. 493.
  61. ↑ cf. Ewert / Wagenhofer, Unternehmensrechnung 2005, p. 617, Friedl, Controlling 2003, p. 494f.
  62. ↑ cf. Ewert / Wagenhofer, company accounting 2005, p. 617.
  63. ↑ cf. Ewert / Wagenhofer, Unternehmensrechnung 2005, p. 618ff.
  64. ↑ cf. Coenenberg, cost accounting 2007, p. 719.
  65. ↑ cf. Küpper, Controlling 2005, p. 398.
  66. ↑ cf. Ewert / Wagenhofer, company accounting 2005, p. 620.
  67. ↑ cf. Schultze / Weiler, Gestaltung 2007, p. 105.
  68. ↑ cf. Schultze / Weiler, Gestaltung 2007, p. 105.
  69. ↑ cf. Theurl / Meyer, Verrechnungspreise 2004, p. 171.
  70. ↑ cf. Ossadnik, Controlling 1998, p. 234.
  71. ↑ See OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010 , pp. 70 ff.
  72. ↑ See OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010 , p. 72 ff.
  73. ↑ See OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010 , p. 78 ff.
  74. ↑ See OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010 , pp. 86 ff.
  75. ↑ See OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010 , pp. 104 ff.
  76. ↑ see Deloitte's Strategy Matrix for Global Transfer Pricing