미국의 移轉價格策定과 덤핑決定價格算定에 관한 比較硏究

A Comparative Study on U.S. Transfer Pricing And Dumping Pricing Calculation

Transfer prices are charged on goods or services transferred among companies belonging to the same group or among divisions of the same entity. These transfers may be viewed as internal sales for which the seller receives a transfer price that is charged to the buyer. When these internal sales are practiced by multinational corporations through foreign subsidiaries, the Question of what price they charge to their affiliates becomes more complex. If transfer prices are used for shifting profits from a country with a higher tax rate to a country with a lower tax rate, they will bring huge economic benefits to the companies manipulating them. However, such practices are under regulations of taxing agencies because they have a great impact on tax revenue and policies of governments concerned. The Internal Revenue Service has targeted a number of U.S. and foreign multinational corporations for investigation, especially Japanese and Korean companies largely because they dominate the foreign entries in the U.S. Dumping regulations and procedures under which ordinary prices and export prices are calculated and compared are similar to those applied to transfer prices. The party which is under dumping investigation should convince an investigator that export prices are ordinary prices in its country, use the most proper method among various ones available to prove it, and go through complex adjustment procedures. These are essential procedures for dumping decision and complex problems arise during the procedures because various commodities are handled under various circumstances. Therefore, related knowledge and negotiation technique is required to cope with it. In this research similarities and differences between transfer prices and dumping prices calculation are compared and studied to understand it better and to raise negotiation ability for it.