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Gaps in tax-based transfer pricing are filled by a second managerial system in measuring divisional profits better.

The CFO of Hewlett-Packard corp's Enterprise Computing Organisation is faced with a problem, demanding his immediate attention. International companies like HP having many divisions spread across different geographical regions face the problem of varying interdivisional transfer-pricing mechanisms, based on various financial and tax-accounting regulations.

Such varying reporting mechanisms complicate the profit recording and compensation systems at the individual branches of the company. Transfer prices, the charges recorded by a company while its units do business with each other, serve to establish the internal profit structure on which taxes are paid. Due to the varying tax regulations prevalent across countries, transfer price reporting in the individual accounts of the branches also vary. This creates major hurdles in consolidating management accounts at the central hub of big international companies.

Accounting made difficult…
In addition to the non-uniformity of tax laws pertaining to accounting and reporting of transfer prices in the books of the branches, regulations allowing managerial discretion in deciding basic factors like charges for general and administrative costs and intangibles among the branches make accounting difficult.

"The biggest problems are when the measured profitability of a business unit has more to do with the skill of its manager in negotiating his transfer prices within the company than its economic profits and the factors that drive shareholder-value creation", says Jay Tredwell, director of CEO Solutions.

Subjective decisions of the manager add to the uncertainty in management reporting. In the past, companies could adjusted their transfer-pricing requirements by yielding the tax rules to suit their business needs. Inadequate monitoring on the part of the regulators made this possible. However, today the regulators, seeking to increase their revenues from taxes have tightened the transfer-pricing policies and tax strategies of companies. r of the Accounts are also monitored regularly.

Owing to the change in the regulators' policies regarding account monitoring procedures, companies are adopting a separate-reporting approach, wherein a second managerial set of transfer-pricing numbers for interdivisional purposes is generated.

Separate reporting approach…
In such a system of reporting, the company maintains two sets of accounts for the transfer pricing transactions, one in compliance with the statutory rules and policies, reflecting the statutory profits, and the other showing the actual profits without reflecting the statutory tax requirements.

Pros…
Such a separate accounting system benefits the overall company, as the managers have a correct picture of individual branch profits and performance. This would then form a base for deciding on the compensation package for the individual branches and managers.

The actual profitability of branches enables the managers at the head office to formulate strategies that would enhance overall branch and company performance.

As an additional benefit, companies with separate management reporting systems findit easier to channel newer, non-traditional income streams to the appropriate products. For instance, at HP, the managers want this new system of reporting to include the increasing flow of transaction-fee type or pay-for-performance models that do not fit into their current transfer pricing and compensation systems. Such increased information in the company accounts gives managers a better picture of the business transactions, enabling further planning and implementation of policies.

Cons…
Small and medium sized companies often cannot afford such a system of separate reporting as the expenditure involved in implementing a parallel accounting system is substantial and could strain the finances of the company. Hence, only financially sound companies can enjoy the above-mentioned benefits.

Certain companies are hesitant in implementing a parallel accounting system as such a system would result in changes to the compensation and divisional bonus systems that may not be accepted by the employees. Non-acceptance of such changes would lead to a resistance on their part thereby affecting their performance.

A case in point…
Microsoft Corp., the software giant, implemented this separate accounting system. This system draws data from a new base of managerial numbers designed to help its leadership team make better decisions on utilisation of its marketing resources, timing of product launch, and minimisation of production costs. The company called its parallel accounting system as Microsoft Accounting Principles (MAPs).

The company basically wanted to make its local marketing managers accountable for the actual profitability of their products, and to establish appropriate marketing spending levels for every line. Hence, they created MAPs, which gives the company a detailed P&L account for each branch. This projects the branch profitability position based on which improvement policies can be framed or managers responsible can be adequately compensated.

Conclusion
Having such a reporting system would help international companies to draw accounts that give a clear picture of their global operations.

Related reading:
"Separate but unequal": Springsteel.I: CFO Magazine.

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