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How can you use transfer pricing methods to support technology transfer in a multinational company?

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Transfer pricing methods are the techniques used to determine the prices of goods and services exchanged between related entities within a multinational company (MNC). They can have a significant impact on the profitability, tax liability, and cash flow of each entity, as well as the overall value of the MNC. One of the key challenges for MNCs is how to use transfer pricing methods to support technology transfer, which is the process of sharing or transferring technological knowledge, skills, or innovations across different entities within the MNC. Technology transfer can enhance the competitive advantage, efficiency, and innovation of the MNC, but it can also entail risks and costs. In this article, you will learn how to use transfer pricing methods to support technology transfer in a MNC, and what factors to consider when choosing the most appropriate method.

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Saheed Makinde ACA, GNIM.

Risk, Control and Compliance Manager / EX-KPMG
Paulo Toyosi Toda Nishimura

Consultant at Blue Jam, Blueberry Jam Toda Nishimura Consultoria e Participa??es Ltda and Real Estate Developer at…
Ishaq M Hassan ACTI

Finance || Taxation || Research

1 Benefits of technology transfer

Technology transfer can offer numerous benefits to MNCs, such as enhancing product quality and performance in multiple markets and regions, reducing R&D expenses, leveraging the expertise and capabilities of different entities within the MNC, fostering collaboration and learning, and enhancing the reputation of the MNC as a leader in innovation and technology. However, there are also challenges and costs associated with technology transfer, including protecting intellectual property rights and confidentiality, ensuring compatibility and compliance with various legal, regulatory, and cultural environments, providing adequate training and support for users of the technology, and managing potential conflicts over ownership, value, and use of the technology.

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Saheed Makinde ACA, GNIM.

Risk, Control and Compliance Manager / EX-KPMG
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Transfer pricing methods can be used to support technology transfer in a multinational company in a number of ways. To allocate the costs and benefits of technology development and transfer between related parties. This can be done using methods such as the cost-plus method, the comparable uncontrolled price (CUP) method, and the transactional net margin method (TNMM). To set the prices of technology transactions between related parties. This can help to ensure that the transactions are arm's length and that the multinational company is not shifting profits to low-tax jurisdictions. To create incentives for related parties to invest in technology development and transfer.

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Paulo Toyosi Toda Nishimura

Consultant at Blue Jam, Blueberry Jam Toda Nishimura Consultoria e Participa??es Ltda and Real Estate Developer at TriNit Family Bunker Built. Construtorá e Incorporaadora Startup.
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Monopoly is the Utópico Goal but Arks are good to protect the Techs. So firstly we need to have control of what we have as market, producers, and heads. It is not up to humans to create them we can only school them. But Society has a crucial role in allowing them to develop. The nature of each person to be Head, Market, producers… is given by God in the person Soul. If Soul controls the Spirit, the Spirit control our mindfulness and the mind control our actions. (APA=American Psychology association). It is God who gives the Talents, it is society who gives the Financial Freedom so people develop it… the ones who end up HEAD, are the ones who control technology. We transfer Heads not technology. If the Heads are inst. then can Tech.B.Trsnfrd

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Ishaq M Hassan ACTI

Finance || Taxation || Research
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Transfer pricing methods in technology can further support multinational companies in several ways tailored to their industry: Intellectual property management R&D allocation Supply chain management. Etc

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2 Transfer pricing methods for technology transfer

Transfer pricing methods can be an effective tool for supporting technology transfer within a MNC, as they provide a way to allocate the costs and benefits of the technology among different entities, while also incentivizing the creation and diffusion of the technology. Depending on the nature, type, and source of the technology, and the objectives and strategies of the MNC, there are several transfer pricing methods that can be applied to technology transfer. These include cost-based methods, which use the costs incurred by the entity that develops or provides the technology as the basis for determining the transfer price; market-based methods, which use prices of comparable or similar technologies available in the open market; and profit-based methods, which use profits generated by the entity that uses or benefits from the technology. Cost-based methods are simple to apply but may not reflect true value or market price. Market-based methods are more realistic and fair, but may be difficult to apply. Profit-based methods are more flexible and aligned with value, but complex and subjective to apply.

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Paulo Toyosi Toda Nishimura

Consultant at Blue Jam, Blueberry Jam Toda Nishimura Consultoria e Participa??es Ltda and Real Estate Developer at TriNit Family Bunker Built. Construtorá e Incorporaadora Startup.
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Transfer Pricing Methods for technology transfer shoul mimic the Cosmos: 1-apps who are just copy paste should be for free of charge or vey low priced because it is like water: for the price of the load only, if the water is transported by truck it should be the cost of the Truck (Diesel, Maintenance, Driver, co-pilot, operators, etc…) 2-Hardware: Chips, Cards, etc… should be very complex and expensive because it has the intel inside and the built in Software who has the Bases Algorithm. It is like Homo God: it is very expensive to upkeep the Lives and intelligent Cogito ergo sum of the Homo God that produces for real and create real wealth and Art. 3-Accessories: should be priced like foods in Menu Design, what we have as a starter…

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3 Factors to consider when choosing a transfer pricing method

Choosing the most appropriate transfer pricing method for technology transfer is not an easy task. It requires careful analysis and evaluation of various factors, such as the nature and characteristics of the technology, the objectives and strategies of the MNC, and the legal and regulatory requirements. For example, a patented technology may have a higher value and lower transferability than a generic technology, while a MNC that wants to encourage innovation may prefer a profit-based method. Additionally, different jurisdictions may have different rules for transfer pricing, such as the arm's length principle or documentation standards. Transfer pricing methods can support technology transfer within a MNC, but they also require careful planning and execution. By understanding these benefits and challenges, you can use transfer pricing methods more effectively and efficiently.

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4 Here’s what else to consider

This is a space to share examples, stories, or insights that don’t fit into any of the previous sections. What else would you like to add?

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Paulo Toyosi Toda Nishimura

Consultant at Blue Jam, Blueberry Jam Toda Nishimura Consultoria e Participa??es Ltda and Real Estate Developer at TriNit Family Bunker Built. Construtorá e Incorporaadora Startup.
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There is a hierarchy in Power when it is about technology AND there is a basal or a rare need when using these same technologies. e.g.:a match is basal. We need it every time it is to turn on the gas stove. a match though does not trump an iPhone so it has less power that the iPhone. Animals don’t revere. Some people behave like animals and thus don’t revere. Therefore we must not allow these irreverent to reach The Most High in Power. Some people are really peaceful and lovely but they suffer in society as a minority who is most civilized: these people should have more access to The Mos Powerful Technology. Companies and manufacturers are temporarily in one status and they are like these two extremes of people: civilized or animal. BWR.

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How can you use transfer pricing methods to support technology transfer in a multinational company?

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1 Benefits of technology transfer

2 Transfer pricing methods for technology transfer

3 Factors to consider when choosing a transfer pricing method

4 Here’s what else to consider

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