International Tool 38

Transfer
Pricing
Margin

Model intercompany transfer pricing between a parent and foreign subsidiary or affiliate. Sets arm's-length pricing, allocates margin across jurisdictions, and flags where the structure may attract tax scrutiny.

1Manufacturing Entity (Parent)

Unit Manufacturing Cost ($)

Parent Overhead Allocation ($)

Parent Tax Rate (%)

2Transfer Price Structure

Transfer Price to Affiliate ($)

Intercompany sell price

Cost-Plus Markup (%)

Arm's-length benchmark

Arm's-Length Transfer Price

3Selling Entity (Affiliate / Sub)

Affiliate Sell Price ($)

Affiliate Operating Cost ($)

Affiliate Tax Rate (%)

Combined After-Tax Margin - parent + affiliate combined

Margin by Entity

Entity	Revenue	Pre-Tax	After-Tax

Transfer Price Sensitivity

Transfer Price	Parent AT	Affiliate AT	Combined

Arm's-length price -

Current vs arm's-length -

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Transfer pricing.Setting intercompany prices that hold up.

Transfer pricing.
Setting intercompany prices that hold up.