DP, a U.S. corporation, has two wholly owned subsidiaries, DS, a U.S. corporation, and FS, a foreign
Question:
DP, a U.S. corporation, has two wholly owned subsidiaries, DS, a U.S. corporation, and FS, a foreign subsidiary incorporated in country X. DS manufactures hammers at a cost of $10 per unit and sells them to FS for $12 per unit. FS sells them to unrelated retailers in country X for $25 per unit. DS also sells the same hammers to Indy, an unrelated tool distributor in the country X, for $16 per unit. DP sells screwdrivers to Indy for $12 per unit and Indy resells the screwdrivers to retailers for $15 per unit in country X. DP also manufactures wrenches for a cost of $5 per unit and sells them to Indy for $7.50 per unit.
What is the appropriate transfer price for the hammers sold by DS to FS using the Comparable Uncontrolled Price Method?
What is the appropriate transfer price for the hammers sold by DS to FS using the Resale Price Method?
What is the appropriate transfer price for the hammers sold by DS to FS using the Cost plus Method?
Principles of Taxation for Business and Investment Planning 2016 Edition
ISBN: 9781259549250
19th edition
Authors: Sally Jones, Shelley Rhoades Catanach