TP FAQs: Positioning of a R&D Company | 研发企业如何进行功能定位
The R&D environment in Malaysia is evolving steadily, partly because of the increased need for R&D as domestic production capacity increases and partly due to the Malaysian government’s incentives for local R&D and innovation activities. In the post-BEPS (Base Erosion and Profit Shifting) era, the question of how multinational companies should organise their Research and […]
TP FAQs: Positioning of a Full-Fledged Trader | 全功能采购商如何定位
Full-Fledged Traders perform supply functions, which involve bargaining, product design and inventory management. The Full-Fledged Traders are exposed to market risk, inventory risk, credit risk and other risks. The Full-Fledged Traders develops local intangible assets regarding supplier relationships and procurement processes. For full-function procurement activities where ownership is held (which usually also involves price negotiation, […]
TP FAQs : Positioning of a Limited-Risk Trader | 有限风险采购商如何定位
Full-fledged manufacturers may be responsible for various tasks, including production planning, input procurement, supply chain management, quality control, long-term capacity utilisation planning, and possibly even selling to third-party clients. Product responsibility, warranty, capacity utilisation, market demand, and pricing risks are some of the risks associated with the operations of a full-fledged manufacturer who holds (non) […]
TP FAQs: Positioning of a Purchasing Agent | 采购代理人如何定位
Purchasing Agents look at the availability of a product or service a company needs and technical support from knowledgeable providers in their fields. When researching the right product for their employer, they consider price and quality to ensure it fits the company’s needs. For the purchasing agent, supplier relationships are not necessarily a very important […]
TP FAQs : How to Evaluate Every Responsibility Centre | 如何判断每一种责任中心
The concept of Responsibility Centres is flexible and can be used to analyse different transactions. It is important to establish the alignment between legal, accounting, and economic reality according to the business model and to determine how the various key functions are divided between the company’s operations. For example, is the function a cost centre […]
TP FAQs: How can we categorise the Responsibility Centres of MNCs | 跨国公司责任中心的分类包括哪些
The design of a transfer pricing system within a multinational group often determines the compensation that can be obtained for the real activities of each subsidiary within the group. Once the functional responsibilities of the participating entities have been clearly identified through functional analysis, these entities should be grouped according to their respective functional attributes […]
TP FAQs: How to determine Legal and Economic Ownership of Intangible Assets | 如何判断无形资产的法律和经济所有权
Ownership of intangible assets includes: The legal ownership of intangible assets refers to the owner of the intangible assets identified through legal registration, contractual agreements, etc. The economic ownership of an intangible asset is the participant in the economic activity who makes a substantial contribution to the value of the intangible asset, i.e. the organisation […]
TP FAQs: Relationship between the Functions Performed and the Returns Received | 履行的功能与获得的回报间的关系
In general, there ought to be a positive correlation between the functionality of a company and the returns that it generates. The more functions that are engaged and risks that are assumed by the company, the higher the expected level of profit should be; nevertheless, the more volatile the expected level of profit will be. Our […]
TP FAQs: Will the enterprise have More Risks with More Functions? | 企业的功能越多是否承担的风险也越多
The question of who takes risky decisions and who bears the consequences of those decisions has always been very important in transfer pricing analysis. Generally, if an enterprise performs a function, it bears the corresponding risk. However, this may not always be the case in individual cases, e.g. R&D activities in contract R&D may not […]
TP FAQs : 企业的功能与风险一定匹配
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