Jumat, 01 Juni 2012

TRANSFER PRICING AND INTERNATIONAL TAXATION


TRANSFER PRICING AND INTERNATIONAL TAXATION

INITIAL CONCEPT
The complexity of the laws and rules that determine the tax for foreign companies and the profits generated abroad actually derived from some basic concepts
1.      Neutrality tax is the that the taxes do not have an influence (or neutral) against the decisions of allocation of resource.
2.      Equity tax is the that the compulsory tax that facing a situation that resemble and the similar undue pay the taxes who same but against of disapproval inter how the implements the this concept.

PROFIT FROM THE SUMBAR taxation abroad,
Some States separti french, costal Rica, hongkong panama south africa, swiss and venezuala apply the principle of territorial taxation and impose taxes on companies that are domiciled in the country that profits generated outside the State. While most countries (including Australia, Brazil, China, Czech Republic, Germany, Japan, Mexico, Netherlands, UK, and Amarika States) to apply the principles throughout the world and impose taxes on profits or income of companies and citizens in it, regardless of the territory of the .

FOREIGN TAX CREDIT
Tax credits can in the estimate if the the amount of income tax outer that nation that they paid will not too unclear (ie when the child companies overseas sends partly profits which sourced from overseas to the the parent domestic companies). Dividends are reported here in the parent company's tax return should be calculated gross (gross-up) to cover the amount of taxes (which are considered paid) plus all foreign levies taxes applicable. This means that as if the parent company receives dividends domestically which includes taxes owed to foreign governments and then pay the tax.
Indirect tax credit allowed foreign (foreign income taxes deemed paid) is determined as follows:
Dividend payments
(Including all tax levies)
x foreign tax can be credited
Profit after tax foreign income

PLANNING TAX IN COMPANY MULTINATIONAL
In the tax planning of multinational companies have certain advantages over a purely domestic firm because it has greater flexibility in determining the geographic location of production and distribution systems. This flexibility provides the opportunity to utilize their own national tax ataryuridis differences so as to lower the overall corporate tax burden.
Observations top of problem planning this tax in began to with two things basic:
1.      Tax considerations should never mengandalikan business strategy
2.      Changes in tax laws are constantly limit the benefits of tax planning in the long term.

VARIABLES IN TRANSFER PRICING
Transfer prices set a monetary value on the exchange between firms that take place between the operating unit and is a substitute for market prices. In general, the transfer price is recorded as revenue by one unit and the unit cost by others. Cross-border transactions of multinational corporations are also open to a number of environmental influences that created the same time destroying the opportunity to increase profits through transfer pricing. A number of variables separti tax rate competition infalsi rates, currency values, limitations on the transfer of funds, political risk and the interests of joint venture partners are very complicated transfer pricing decisions.

TAX FACTOR
Reasonable transaction price is the price to be received by parties not related to special items the same or similar in the exact same situation or similar. Reasonable method of determining the transaction price that is acceptable is:
1.      the method of determining the comparable uncontrolled price.
2.      method of determining the resale price.
3.      plus the cost price determination methods and
4.      other methods of assessment rates

DEFINITION FACTOR
Tariffs for imported goods also affect transfer pricing policies of multinational corporations. In addition to the balance didentifikasikan, mulinasional companies should consider the costs and benefits, both internal an external. High tax rates paid by the importer will generate the income tax base is lower.

Competitiveness Factors
Similarly, a lower transfer price can be used to protect the ongoing operation of the influence of foreign competition is increasingly tied to the local market or other markets. Considerations the competitiveness like it should be be balanced against against many losses which result vice versa. Transfer rates for competitive reasons may invite anti-trust action by the government.

Performance Evaluation Factors
Transfer pricing policy is also influenced by their influence on behavior management and is often the main determinant of company performance.

Accounting for Contributions
The management accountant can mamainkan a significant role in calculating the balance (trade-offs) in transfer pricing strategies. The challenge is to maintain a global perspective when mapping the benefits and costs associated with determining pricing decisions

TRANSFER PRICING METHODOLOGY
In a world with very competitive transfer rates, it will be a big deal when they wanted to transfer pricing resources and services between firms. However, there is rarely a competitive external market for products that are transferred between related entities is special. Problem of determining these costs are felt in the international level, because the concept of cost accounting is different from one country to another.

Principle of Fair
A common type of multinational companies is the integration operation. Subsidiaries are in the same control as well as sharing the same source and destination. The need to declare taxable income in different countries means that multinational companies must allocate income and expenses among subsidiaries and determining transfer prices for transactions between companies.

Source :

FINANCIAL RISK MANAGEMENT IN INTERNATIONAL ACCOUNTING


FINANCIAL RISK MANAGEMENT IN INTERNATIONAL ACCOUNTING

FUNDAMENTAL THINGS
Main objectives of financial risk management is to minimize the potential loss arising from unexpected changes in currency rates, credit, commodities, and equities. The risk of price volatility faced is known as market risk.

Market participants tend not to take risks. Intermediary financial services and a market maker responds by creating a financial product that allows a trader to shift the risk of unexpected price changes to others-the other side.

There is market risk in various forms, other risks:
1.      Liquidity risk arises because not all the financial risk management products can be traded freely. Highly illiquid market is such as real estate and stocks with small capitalization.
2.       Market discontinuity refers to the risk that the market does not always lead to price changes to survive. Stock market crash in 2000 is a case in point.
3.      Credit risk is the possibility that the other party in the contract risk management can not meet its obligations. For example, the parties agree to exchange the euro versus the French into the Canadian dollar may fail to submit the euro on the date promised.
4.      Regulatory risk is the risk arising from public authorities banned the use of a financial product for a particular purpose. For example, Kuala Lumpur stock exchange does not allow the use of shrot sales as a means of hedging against the decline in equity prices.
5.      Tax risk is the risk that certain hedging transactions can not obtain the desired tax treatment. For example, treatment of foreign exchange losses as capital gains as ordinary income to be preferred.
6.      Accounting risk is the chance that a hedging transaction can not be recorded as part of the transaction is hedged about. An example is when the advantage over a hedge against the purchase commitments are treated sebgaai "other income" rather than as a reduction of purchasing costs.

MANAGING FINANCIAL RISK WHY?
The growth of risk management services that quickly shows that management can enhance shareholder value by controlling the financial risk. If the value of the company to match the present value of future cash flows, active management of potential risks can be justified by several reasons.
First, exposure management helped in stabilizing the company's cash flow expectations. Flow is more stable cash flows that can minimize earnings surprises thus increasing the present value of expected cash flows. Active exposure management allows companies to concentrate on the major business risks.
Lenders, employees and customers also benefit from exposure management. Finally, because of losses caused by price and interest rate risk of certain transferred to the customer in the form of higher prices, limiting exposure management of risks faced by consumers.

THE ROLE OF ACCOUNTING
Management accountants to help in the identification of market exposure, quantify the balance associated with alternative risk response strategy, the company faced a potential measure of risk, noting certain hedging products and evaluate the effectiveness of the hedging program.
1.      Identification of Market Risk
The basic framework is useful for identifying different types of market risk that could potentially be referred to as risk mapping. This framework begins with the observation of the relationship of the various market risks triggering a company's value and its competitors. And usually referred to as cube mapping risk. The term trigger value refers to the financial condition and performance items that affect the financial operations of the main value of a company. Market risks include the risk of foreign exchange rates and interest rates, and commodity price risk and eukuitas. The third dimension of the cube mapping risk, look at the possible relationship between market risk and trigger values ​​for each of the company's main competitor.
If a competitor to buy baseball caps from abroad and the country's currency depreciates in value purchase source relative to the currency of your country, then these changes can cause your competitors are able to sell at lower prices than you. This is referred to as the risk of facing currency competitive.
2.      Balancing quantify
Another role played by accountants in the process of risk management involves balancing the quantification process relating to the alternative risk response strategies. Accountants must measure the benefits of protected areas assessed and compared to the cost plus the opportunity cost of lost profits from speculation and market movements
3.      Risk Management in the World with a Floating Exchange Rate
The risk of foreign exchange (forex) is one of the most common form of risk and will be faced by multinational companies. In a world of floating exchange rates, risk management include:
            a.       anticipation of exchange rate movements,
            b.      measurement of exchange rate risks facing the company,
            c.       design of appropriate protection strategies, and
            d.      the manufacture of internal risk management controls.

Source :
http://ikapurple.blogspot.com/2011/05/manajemen-risiko-keuangan-dalam.html

MANAGEMENT PLANNING AND CONTROL THE INTERNATIONAL ACCOUNTING


MANAGEMENT PLANNING AND CONTROL THE INTERNATIONAL ACCOUNTING

Global competition that occurs along with advances in technology are constantly changing significantly the scope of business and internal reporting requirements. Reduction in national trade barriers on an ongoing basis, a floating currency, sovereign risk, restrictions on sending funds across national borders, differences in national tax systems, the difference in interest rates and commodity prices and the effect of changing equity to assets, earnings , and the cost of capital is a variable that complicates management decisions. At the same time, developments such as the Internet, video conferencing, and electronic transfer change the economics of production, distribution, and financing. Global competition and rapid dissemination of information to support the limited national differences in management accounting practices. Additional pressures include, among others, changes in markets and technologies, the growth of privatization, incentive costs, and performance, and coordination of global operations through joint ventures (joint ventures) and other strategic links. Does it improve the management of multinational companies to not only implement internal accounting techniques that can be compared, but also use these techniques in the same way.

MAKING BUSINESS MODEL
The latest survey found that management accountants spend more time in strategic planning issues than before. Determination of the business model of the big picture, and consists of the formulation, implementation and evaluation of long-term business plan of a company. It includes four main dimensions.
1.      Identify the major factors relevant to the company's progress in the future.
2.   Formulate an adequate technique to predict future developments and analyze the company's ability to adapt or take advantage of these developments.
3.      Develop data sources for menditkung strategic choices.
4.      Certain choices translate into a series of specific actions.

PLANNING TOOL
In identifying the relevant factors in the future, scanning the external and internal environment will greatly assist companies in recognizing the challenges and opportunities. A system can be applied to gather information on competitors and market conditions. Both competitors and market conditions are analyzed to see the influence of both the standing of the competition and the level of corporate profits. Inputs obtained from this analysis are used to plan the measures used to maintain or increase market share or to recognize and utilize the new product and market opportunities.

One such tool is the WOTS-UP analysis. This Analicis regarding the strengths and weaknesses of the company relating to the company's operating environment. This technique helps in generating a series of management strategies that can be run.

Decision tools that are currently used in the strategic planning system relies entirely on the quality of information about internal and external environment of an enterprise. Accountants can help corporate planners to obtain useful data in strategic planning decisions. Most of the required information comes from sources other than the accounting records.

CAPITAL BUDGET
The decision to invest abroad is a very important element in the global strategy of a multinational company. Foreign direct investment generally involves large amounts of capital and the prospects are uncertain. Investment risk, followed by the foreign environment, complex and constantly changing. Formal planning is a must and is generally performed in a capital budgeting framework that compares the benefits and costs of the proposed investment.

Approach to more complex investment decisions are also available. There are several procedures to determine the optimum capital structure of a company, measuring the cost of capital of a company, and evaluate investment alternatives under conditions of uncertainty. Decision rule for investment options generally require a discounted cash flow investment based on risk-adjusted interest rates are adequate: the weighted average cost of capital. Generally, companies can increase the prosperity of the owner to make an investment that promises a positive net present value. When considering the options that are mutually separated or mutually independent (mutually exclusive), a rational firm will choose the option that promises the net present value of the maximum possible.

In the international environment, investment planning is not as simple as that. Huokum differences in tax, accounting system, the rate of inflation, the risk of nationalization, currency framework, market segmentation, restrictions on the transfer of retained earnings, and differences in language and culture adds to the complexity of elements that are rarely found in domestic environments. The difficulty for the quantification of these data make existing problems worse.

Adaptation (adjustment) by multinational companies for investment planning models have traditionally been carried out in three areas of measurement: (1) determine the relevant returns for multinational investments, (2) measure of cash flow expectations, and (3) calculate the cost of multinational capital. This adaptation provides data that support the strategic choices, the third step in the process of enterprise modeling.

VIEWPOINT FINANCIAL RESULTS
A manager must determine the rate of return that are relevant for analyzing foreign investment opportunities. However, the relevant rate of return is a matter of perspective. Should the international financial manager to evaluate expectations of return on investment from the standpoint of foreign project or from the perspective of the parent company? Returns from these two viewpoints may differ significantly due to several reasons such as: (1) restrictions on repatriation of profits by the government and capital, (2) license fees, royalties and other payments which is the profit for the parent company but is a burden for subsidiaries , (3) differences in national inflation rate, (4) changes in exchange rates acing, and (5) differences in taxes.

Opinion that the rate of return and the risk of a foreign investment can be evaluated from the viewpoint of the parent company's domestic shareholders, are no longer sufficient because:
1.      Investors in the parent company of the more that comes from the world community.
2.    Investment objectives must reflect the interests of all shareholders, not just from domestic.
3.  Observations also show that multinational companies have long-term investment horizon '(and not short term). Funds generated abroad tend to be reinvested rather than repatriated to the parent company. Under these conditions, would be more appropriate to evaluate the return from the standpoint of the host country. The emphasis on local projects of return consistent with the objective to maximize the value of the consolidated group.

Adequate solution is to recognize that financial managers must meet multiple objectives, by providing a response to investor groups and noninvestor in organization and in its environment. Host country governments is one of the group for foreign investment. Match between the goals of multinational investors and host countries should be achieved through two financial return calculations: one from the standpoint of the host country, and the other from the viewpoint of the parent company. The host country's point of view assumes that a favorable foreign investment (including capital costs of local opportunities) would not be wrong in allocating resources of the host country are scarce. Evaluation of investment opportunities from the local viewpoint also provides useful information for the parent company.
If a foreign investment does not promise a return on risk adjusted value is higher than the return obtained by a local competitor, then the parent company's shareholders would be better to invest directly in local companies.

Source :
http://ikapurple.blogspot.com/2011/05/perencanaan-dan-kendali-manajemen-pada.html