Transfer price: Meaning, types, benefits and more

Large mother companies strive to gain profits while reducing the cost of doing business to the minimum. Two companies may trade among themselves using a price that is different from the market price.

In this article, we will explore the concept of transfer pricing, how it works, and its potential impact on businesses and economies.

What is transfer price?

Transfer pricing is a term used to describe the pricing of goods or services when they are transferred between different entities within the same company. This practice is common among multinational corporations, as it allows them to move profits and costs between countries to minimize taxes and increase overall profitability. 

Types of transfer pricing and their differences 

1. Cost-based transfer pricing

This type of transfer pricing involves setting prices based on the cost of production, including direct costs (such as raw materials and labour) and indirect costs (such as overhead and administrative expenses).

It is generally considered the simplest method of transfer pricing, but may not always accurately reflect the true value of the transferred goods or services.

2. Market-based transfer pricing

This method involves setting prices based on prevailing market rates for similar goods or services. It assumes that the market price is the best indicator of the value of the transferred goods or services, and is often used when comparable transactions can be easily identified.

3. Profit-based transfer pricing

This approach involves setting prices based on the profit margin expected by the transferring entity.

This can be calculated as a percentage of the cost of production or the market price and is often used by multinational corporations to allocate profits between different subsidiaries in different countries.

4. Negotiated transfer pricing

This approach involves setting prices through negotiation between the transferring and receiving entities.

It can be used when there are no clear market rates or when the parties involved have a close relationship.

5. Administrative pricing

This method involves setting prices based on a predetermined formula or set of rules, often established by a government or regulatory agency.

This approach is typically used in industries that are heavily regulated, such as utilities or telecommunications.

6. Dual pricing

This approach involves setting different prices for the same goods or services, depending on whether they are being sold to an internal or external customer.

This method can help ensure that internal transactions are properly accounted for, but can also create inconsistencies and potential legal issues.

The benefits and risks of transfer pricing for businesses 

The benefits and risks of transfer pricing for businesses can be significant. On the one hand, transfer pricing can help companies optimize their tax liabilities, improve financial performance, and allocate costs and profits across different subsidiaries and jurisdictions. It can also provide a means for companies to better manage their global operations and supply chains.

However, transfer pricing can also pose several risks for businesses, particularly in terms of compliance and reputation. Improper transfer pricing can result in tax liabilities, penalties, and legal disputes with tax authorities. In addition, it can damage a company’s reputation and relationships with stakeholders, including customers, suppliers, and investors.

There are also broader implications of transfer pricing for global economies. Some critics argue that transfer pricing can distort trade flows, reduce tax revenues for developing countries, and erode public trust in the fairness of the global tax system. Others argue that transfer pricing can encourage investment and innovation, and support economic growth.

To mitigate the risks of transfer pricing, companies should ensure that their transfer pricing policies and practices comply with relevant laws and regulations. This may involve conducting transfer pricing studies, documenting transfer pricing policies and transactions, and engaging with tax authorities as needed. Companies should also consider the potential reputational risks of transfer pricing and ensure that their policies and practices align with their corporate values and ethics.

The impact of transfer pricing on global economies 

The impact of transfer pricing on global economies is a topic of ongoing debate among policymakers, academics, and business leaders. Some argue that transfer pricing allows multinational corporations to shift profits and costs between different countries, often in ways that reduce their overall tax liabilities. This can result in reduced tax revenues for governments, particularly in developing countries, and can exacerbate economic inequality.

At the same time, others argue that transfer pricing can encourage investment and innovation, and support economic growth. By allowing companies to optimize their operations and allocate resources more efficiently, transfer pricing can enhance competitiveness and create jobs. Moreover, by reducing the tax burden on businesses, transfer pricing can free up resources for investment and expansion, which can in turn benefit the broader economy.

Despite these potential benefits, transfer pricing remains a contentious issue. Many countries have established regulations and guidelines for transfer pricing to ensure that companies are not abusing the system to evade taxes or engage in other unethical practices. However, enforcing these regulations can be challenging, particularly in the face of complex global supply chains and evolving business practices. As such, the impact of transfer pricing on global economies will continue to be a subject of debate and scrutiny in the years to come.

Regulatory frameworks and guidelines for transfer pricing 

Regulatory frameworks and guidelines for transfer pricing have been established by various governments and international organizations to ensure that multinational corporations are paying their fair share of taxes and complying with ethical business practices.

These frameworks and guidelines typically aim to provide a standardized and transparent approach to transfer pricing and to prevent companies from engaging in tax avoidance or other unethical behaviour. They may include requirements for documentation and disclosure of transfer pricing policies and transactions, as well as guidelines for the selection of appropriate transfer pricing methods.

Some of the key international bodies involved in the development of transfer pricing guidelines include the Organisation for Economic Co-operation and Development (OECD), the United Nations Committee on International Trade Law (UNCITRAL), and the World Customs Organization (WCO).

In addition to these international organizations, many countries have established their transfer pricing regulations and guidelines. These regulations may be influenced by international guidelines, but may also reflect local economic conditions and priorities. For example, some countries may place greater emphasis on protecting domestic tax revenues, while others may focus more on promoting investment and innovation.


Transfer pricing is a complex and often a controversial issue that can have significant implications for businesses and global economies. While transfer pricing can offer benefits in terms of tax optimization and operational efficiency, it also carries risks related to compliance and reputation.

Ultimately, companies should strive to ensure that their transfer pricing practices are ethical, transparent, and in compliance with relevant regulations and guidelines.

Frequently Asked Questions (FAQs)

Can transfer pricing be used to reduce tax?

One of the major benefit of transfer pricing is that it helps the parent company reduce its tax burden, especially if one of the trading subsidiary companies is located in a tax friendly country.

Can transfer pricing be higher than the market price?

Yes, transfer price need not be low, it can also be higher than the market price.

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Richard Okoroafor

Richard Okoroafor

Richard is a brilliant legal content writer who doubles as a finance lawyer. He brings his wealth of legal knowledge in corporate commercial transactions to bear, offering the best value that exceeds expectations.

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