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1.How to Identify and Allocate Them?[Original Blog]

One of the key challenges in transfer pricing is how to allocate costs between related entities that engage in transactions with each other. Costs can be classified into two broad categories: direct and indirect costs. Direct costs are those that can be easily traced to a specific product, service, or activity. Indirect costs are those that cannot be easily traced to a specific product, service, or activity, but are incurred for the benefit of the whole organization or multiple products, services, or activities. In this section, we will discuss how to identify and allocate direct and indirect costs in transfer pricing, and what are the implications of different methods of cost allocation.

Some of the points that we will cover are:

1. How to identify direct and indirect costs. The first step in cost allocation is to identify which costs are direct and which are indirect. This can be done by using the cost traceability criterion, which states that a cost is direct if it can be traced to a specific cost object (such as a product, service, or activity) in an economically feasible way. A cost is indirect if it cannot be traced to a specific cost object, or if the tracing process is too costly or impractical. For example, the cost of raw materials used to produce a product is a direct cost, while the cost of electricity used to run the factory is an indirect cost.

2. How to allocate indirect costs. The next step in cost allocation is to allocate indirect costs to the relevant cost objects. This can be done by using different methods, such as the direct method, the step-down method, the reciprocal method, or the activity-based costing method. These methods differ in how they treat the interrelationships among different cost centers (such as departments or divisions) that incur and share indirect costs. For example, the direct method ignores the interrelationships and allocates indirect costs based on a single allocation base (such as sales, output, or labor hours). The step-down method recognizes some of the interrelationships and allocates indirect costs in a sequential manner, starting from the cost center that provides the most services to other cost centers. The reciprocal method recognizes all of the interrelationships and allocates indirect costs using a system of simultaneous equations. The activity-based costing method allocates indirect costs based on the activities that cause them, and the cost drivers that measure the consumption of those activities.

3. What are the implications of different methods of cost allocation. The choice of the method of cost allocation can have significant implications for the transfer pricing outcomes, such as the profitability, tax liability, and competitiveness of the related entities. Different methods of cost allocation can result in different amounts of indirect costs being allocated to different cost objects, which can affect the transfer prices and the margins of the related entities. For example, using the direct method can result in lower indirect costs being allocated to the cost objects that receive more services from other cost centers, which can result in lower transfer prices and higher margins for those cost objects. Using the reciprocal method can result in higher indirect costs being allocated to the cost objects that provide more services to other cost centers, which can result in higher transfer prices and lower margins for those cost objects. Using the activity-based costing method can result in more accurate and fair allocation of indirect costs, which can result in more realistic transfer prices and margins for the cost objects.

4. How to choose the best method of cost allocation. The best method of cost allocation depends on the objectives, circumstances, and preferences of the related entities. Some of the factors that can influence the choice of the method of cost allocation are:

- The degree of complexity and interdependence of the cost centers and the cost objects.

- The availability and reliability of the data and the information systems.

- The cost and benefit of implementing and maintaining the method of cost allocation.

- The alignment of the method of cost allocation with the organizational goals and strategies.

- The compliance with the transfer pricing regulations and the arm's length principle.

To illustrate some of the points discussed above, let us consider an example of a multinational company that has two related entities: Entity A and Entity B. Entity A produces and sells widgets, and Entity B provides marketing and distribution services to Entity A. The following table shows the direct and indirect costs incurred by Entity A and Entity B for the year 2024.

| Cost Center | direct costs | Indirect Costs |

| Entity A | $100,000 | $50,000 |

| Entity B | $80,000 | $40,000 |

| Total | $180,000 | $90,000 |

The indirect costs of Entity A include the costs of administration, finance, and human resources. The indirect costs of Entity B include the costs of advertising, transportation, and warehousing. The following table shows the percentage of services provided by each cost center to each cost object.

| Cost Center | Entity A | Entity B |

| Entity A | 100% | 20% |

| Entity B | 80% | 100% |

Using the direct method, the indirect costs of Entity A and Entity B are allocated as follows:

| Cost Object | Indirect Costs Allocated by Entity A | Indirect Costs Allocated by Entity B | Total Indirect Costs Allocated |

| Entity A | $50,000 x 100% = $50,000 | $40,000 x 80% = $32,000 | $82,000 |

| Entity B | $50,000 x 20% = $10,000 | $40,000 x 100% = $40,000 | $50,000 |

| Total | $60,000 | $72,000 | $132,000 |

Using the step-down method, the indirect costs of Entity A and Entity B are allocated as follows:

| Cost Object | Indirect Costs Allocated by Entity A | Indirect Costs Allocated by Entity B | Total Indirect Costs Allocated |

| Entity A | $50,000 x 100% = $50,000 | $40,000 x 80% + $10,000 x 80% = $40,000 | $90,000 |

| Entity B | $50,000 x 20% = $10,000 | $40,000 x 100% + $10,000 x 20% = $42,000 | $52,000 |

| Total | $60,000 | $82,000 | $142,000 |

Using the reciprocal method, the indirect costs of Entity A and Entity B are allocated as follows:

| Cost Object | Indirect Costs Allocated by Entity A | Indirect Costs Allocated by Entity B | Total Indirect Costs Allocated |

| Entity A | $50,000 + $8,000 = $58,000 | $40,000 + $11,600 = $51,600 | $109,600 |

| Entity B | $10,000 + $1,600 = $11,600 | $40,000 + $8,000 = $48,000 | $59,600 |

| Total | $69,600 | $99,600 | $169,200 |

Using the activity-based costing method, the indirect costs of Entity A and Entity B are allocated as follows:

| Cost Object | Indirect Costs Allocated by Entity A | Indirect Costs Allocated by Entity B | Total Indirect Costs Allocated |

| Entity A | $25,000 + $15,000 + $10,000 = $50,000 | $20,000 + $12,000 + $8,000 = $40,000 | $90,000 |

| Entity B | $5,000 + $3,000 + $2,000 = $10,000 | $10,000 + $6,000 + $4,000 = $20,000 | $30,000 |

| Total | $60,000 | $60,000 | $120,000 |

The activity-based costing method assumes that the indirect costs of Entity A are driven by three activities: production, finance, and human resources. The indirect costs of Entity B are driven by three activities: advertising, transportation, and warehousing. The following table shows the cost drivers and the consumption rates of the activities by the cost objects.

| Activity | Cost Driver | Entity A | Entity B |

| Production | Output | 10,000 | 8,000 |

| Finance | Sales | $200,000 | $160,000 |

| Human Resources | Employees | 50 | 40 |

| Advertising | Ad Views | 2,000,000 | 1,000,000 |

| Transportation | Miles | 20,000 | 10,000 |

| Warehousing | Storage Days | 1,000 | 500 |

The following table shows the cost per unit of the cost drivers and the indirect costs allocated by each activity.

| Activity | Cost per Unit of Cost Driver | Indirect Costs Allocated by Activity |

| Production | $50,000 / 18,000 = $2.78 | $2.78 x Output |

| Finance | $15,000 / $360,000 = $0.042 | $0.

How to Identify and Allocate Them - Cost Allocation in Transfer Pricing: How to Allocate Costs Between Related Entities

How to Identify and Allocate Them - Cost Allocation in Transfer Pricing: How to Allocate Costs Between Related Entities


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