Managing Global Supply Chain: Transfer Pricing Issues and Solutions

Abstract

World trade of goods and services is based upon the global supply chain and logistics management, and its flow is determined by the drivers of supply chain management. For a company to be successful in the new millennium where a paradigm shift has taken place it becomes necessary that its supply chain strategy gets fit with its competitive strategy so as to strike an appropriate balance between the supply chain’s efficiency and responsiveness. One of the supply chain management’s drivers, to achieve this fit is known as “Pricing”. In the context of global supply chain management, Transfer Pricing, with its components such as Arm’s Length Pricing (ALP), Advance Pricing Agreement (APA), Safe Harbour Rules (SHRs), etc. play a very important role and, therefore, in this paper an attempt has been made to explain issues relating to transfer pricing vis-à-vis solution for the same, so that MNEs may operate and supply their tangibles and intangibles to their related companies globally without having any disputes / litigations with a the taxation authorities.

Note: The paper has been uploaded with the permission of its publishers viz. International Journal of Management, Public Policy and Research, Department of Public Policy and Governance, B K School of Professional & Management Studies, Gujarat University, Ahmedabad.

Keywords: Global Supply Chain Management, Transfer Pricing, Abuse of transfer Pricing, Arm’s length pricing (ALP), Abuse of Transfer Pricing, Advance Pricing Agreement (APA), Safe Harbour Rules (SHRs), Mutual Agreement Procedure (MAP)

JEL Classification: E62, F21, F2, F23, H2, H26, H32, H87