JP3212309U - In-house consulting system for creating transfer price documents - Google Patents

Abstract

A transfer price document creation in-house consulting system capable of providing know-how for creating a transfer price document in a company without relying on an expert. A transfer price document creation in-house consulting system for transferring document creation know-how related to a transfer price tax system of an enterprise, the input device 12 for inputting information about the enterprise, and the enterprise input by the input device And an output device 16 for outputting the optimum method for calculating the price between independent companies calculated by the calculation device. [Selection] Figure 1

Description

  The present invention relates to an in-house consulting system for creating transfer price documents.

  Traditionally, the transfer pricing tax system has been introduced in Japan with reference to systems in other countries including the United States. In recent years, substantial transfer pricing documentation rules have been introduced in the tax system revision from the viewpoint of clarifying transfer pricing taxation procedures. Against this background, implementation of transfer price documentation has become an issue not only for large companies that are expanding overseas, but also for small and medium-sized companies.

  As a technique related to the present invention, for example, Patent Document 1 discloses a system for supporting a management strategy of a financial institution, which includes a profit management module, and the profit management module is transferred within the financial institution. A configuration further including a TP performance management module for managing the performance of the price (TP) is disclosed.

JP 2006-129053 A

  In order to prepare transfer pricing documents, it is often requested to ask specialists such as tax accountants and certified public accountants who are familiar with the transfer pricing tax system, but the outsourcing costs are often high, and there is a large amount of financial resources. Regardless of the company, it is a big burden for small and medium-sized companies.

  For this reason, it is required to supply a transfer price document creation in-house consulting system that can provide know-how for creating a transfer price document in a company without relying on an expert.

  The transfer price document creation in-house consulting system according to the present invention is a transfer price document creation in-house consulting system for transferring document creation know-how regarding the transfer price tax system of a company, and inputs information on the company. An input unit; and an output unit that obtains and outputs an optimal inter-company price calculation method based on information about the company input by the input unit.

  The transfer price document creation in-house consulting system according to the present invention preferably further includes a moving image distribution unit for distributing a moving image for transferring the document creation know-how.

  Further, in the in-house consulting system for creating transfer price documents according to the present invention, the optimum method for calculating the price between independent companies is the independent price comparison method, the resale price reference method, the cost reference method, the transaction unit operating profit method, The contribution profit split method, the comparative profit split method, or the residual profit split method is preferable.

  According to the present invention, since an optimum price calculation method for an independent company is calculated based on the information on the company, the person in charge of the company can obtain the know-how of document preparation concerning the transfer price tax system of the company. .

It is a block diagram of the transfer price document preparation in-house consulting system of embodiment which concerns on this invention. It is a flowchart at the time of calculating | requiring the optimal calculation method between independent companies in the transfer price document preparation in-house consulting system of embodiment which concerns on this invention. It is the list | wrist which verified the function and risk which a company has as company information in the transfer price document preparation in-house consulting system of embodiment which concerns on this invention. In the in-house consulting system for transfer price document creation according to the embodiment of the present invention, a list verifying intangible assets as company information, a list verifying the discoverability of comparison transactions, and the total profit between parent and child It is a table | surface of the candidate of the division factor at the time of dividing | segmenting. It is the list | wrist which verified the optimal independent price calculation method in the transfer price document preparation in-house consulting system of embodiment which concerns on this invention.

  Embodiments according to the present invention will be described below in detail with reference to the accompanying drawings. Below, the same code | symbol is attached | subjected to the same element in all the drawings, and the overlapping description is abbreviate | omitted. In the description in the text, the symbols described before are used as necessary.

  FIG. 1 is a configuration diagram of a transfer price document creation in-house consulting system 10. FIG. 2 is a flowchart for obtaining an optimal inter-company price calculation method in the transfer price document creation in-house consulting system 10. FIG. 3 is a list in which functions and risks of a company are verified as company information in the transfer price document creation in-house consulting system 10.

  FIG. 4 divides the total profit between the parent and the child in the transfer price document creation in-house consulting system 10 that verifies the intangible assets as the company information, the list that verifies the discoverability of the comparison transaction It is a list of candidates for division factors. FIG. 5 is a table in which the optimal independent price calculation method is verified in the transfer price document creation in-house consulting system 10.

  The transfer price document creation in-house consulting system 10 includes an input unit 12, a moving image distribution unit 14, and an output unit 16. The transfer price document creation in-house consulting system 10 has a function of providing know-how for creating a transfer price document in a company without depending on an expert.

  The input unit 12 has a function for a person in charge of a company to input information about the company. As the information about the company, for example, the input items necessary to display the verification results of the functions performed by the parent company and the subsidiary as shown in FIG. Further, input items necessary for displaying the verification results of intangible asset verification, comparability verification, and division factor verification as shown in FIG. 4 in a list form are also input.

  For example, in a company having a head office in Japan and a subsidiary in an overseas country, verification is performed by inputting information for classifying the roles played by each company. For example, consider whether the head office or the subsidiary is responsible for research and development functions, manufacturing functions, sales / marketing functions, general management functions, and the risks borne by each related party.

  The research and development function is classified into basic research and product development. For example, when the head office has the function as shown in FIG. 3, the head office is checked. Manufacturing functions are classified into production planning, manufacturing equipment procurement, raw material procurement, processing and assembly, and quality control. This manufacturing function will be described assuming that the head office has a function in this example.

  Sales / marketing functions are classified into market research, sales strategy planning, advertising, customer negotiations, complaint handling, and follow-up. In the example of FIG. 3, the head office has functions for market research and sales strategy planning, and the subsidiary has functions for negotiation with customers, complaint handling, and after-following.

  “O” in the example of FIG. 3 means that the main function is being performed or risk is taken, and “Δ” means that the limited function is being carried out or risk is taken. Here, the advertisement has a limited function such that the subsidiary is indicated by “Δ”. In the following, for items corresponding to △, “limited” functions or “limited” risks will be described.

  General management functions are classified into accounting finance, legal affairs, human resources, and IT. In the example of FIG. 3, these functions have functions not only at the head office but also at subsidiaries, but the subsidiaries have limited functions for legal affairs, human resources, and IT.

  The risks borne by each party are classified into R & D failures, capital investment failures, product liability risks, inventory risks, currency risks, credit risks, and market risks. In the example of Fig. 3, R & D failure, capital investment failure, product liability risk, exchange rate risk is assumed by the head office, inventory risk is limited by the subsidiary, credit risk, market risk is assumed by the subsidiary. Take risks.

  In the example of FIG. 3, it is determined that the function and risk that are fulfilled are simpler for the subsidiary.

  Next, the intangible assets of the head office and subsidiaries will be examined. For example, candidates for intangible assets include manufacturing know-how, patent rights, brand names, and sales networks. Whether these intangible assets are owned by the head office or a subsidiary is verified.

  In the example of FIG. 4, the manufacturing know-how is owned by the head office, and it is predicted that this intangible asset contributes very much to profits. In addition, patent rights, etc. are owned by the head office, and it is predicted that the contribution to profits from patented technology will be very high.

  The brand name is owned by the headquarters and is expected to be very high in terms of contribution to profits from the brand name. Furthermore, the sales network will be owned by a subsidiary and its contribution to profits will be moderate.

  In the example of FIG. 4, it is determined that all important intangible assets are held by the head office.

  Next, the possibility of finding the comparison target transaction is verified. For example, the selling price of similar products, the markup rate for manufacturing costs, the gross margin deducted from the resale price, the operating margin of similar companies, and the profit-sharing ratio of sellers and buyers in third-party transactions It is done.

  In the example of FIG. 4, regarding the selling price of the same type of product, it is considered that an internal comparison cannot be found and an external comparison cannot be found. In addition, as a markup rate against the manufacturing cost, internal comparison is possible for some products, but external comparison is undiscoverable.

  As gross profit margin to be deducted from resale price, internal comparison cannot be found and external comparison cannot be found. The operating profit margin of similar companies is considered possible at the head office and subsidiaries. We believe that the profit-sharing ratio between sellers and buyers in third-party transactions is undiscoverable.

  Next, we will consider candidates for splitting factors when splitting the combined profit between parents and children. In the example of FIG. 4, when R & D expenses are adopted at the head office and personnel expenses are adopted at the subsidiary as factors for adding up, the appropriateness as the division factor is assumed to be medium.

  As another split factor, if the head office adopts R & D expenses + depreciation expenses, and employs labor costs + advertising expenses, the degree of suitability as a split factor is not so high.

  Information on the company as described above is input via the input unit 12.

  The output unit 16 obtains and outputs an optimum method for calculating the price between independent companies based on the information about the company input by the input unit 12. The optimal method for calculating the price between independent companies is the independent price ratio method, the resale price method, the cost method, the transaction unit operating profit method, the contribution profit split method, the comparative profit split method, or the residual profit split method. Select one of them.

  The output unit 16 calculates an optimum method for calculating the price between independent companies based on the information on the company, and an example of a procedure for calculating using the flowchart in FIG. 2 will be described.

  First, it is confirmed whether or not the transaction price between third parties of the same kind of inventory as the inventory with which a related party transaction is performed is known (S2). When the process of S2 is YES, the independent price comparison method is left as a candidate (S4).

  If the process of S2 is NO, for inventories of the same type or similar to the inventories with which the related parties are conducting transactions, the functions and risks held by each related party are highly similar. It is confirmed whether or not the cost markup rate (profit rate added to the manufacturing cost) is known (S6). When the process of S6 is YES, the cost standard method is left as a candidate (S8).

  If the process in S6 is NO, for inventories of the same type or similar to the inventories with which related parties are engaged, transactions with third parties that are highly similar to the functions and risks of each related party It is confirmed whether or not the resale profit rate (the profit rate added to the purchase cost when the buyer of the related party transaction resells to a third party) is known (S10). When the process of S10 is YES, the resale price standard method is left as a candidate (S12).

  When the process of S10 is NO, it is confirmed whether or not the operating profit ratio of the company that handles the same or similar inventory as the inventory that is engaged in the transaction between the related parties can be found from the public data. (S14). When the process of S14 is YES, the transaction unit operating profit method is left as a candidate (S16).

  If the process of S14 is NO, for the third-party transaction dealing with the same or similar inventory with the related party transaction, the split ratio of the seller's and buyer's profits of the transaction is found It is confirmed whether or not (S18). If the process of S18 is YES, the comparative profit split method is left as a candidate (S20).

  When the process of S18 is NO, it is confirmed whether or not there is a division factor for dividing the total profit of the inter-party transaction with a certain degree of reliability (S22). When the process of S22 is YES, the contribution profit split method is left as a candidate (S24).

  If the process of S22 is NO, when the profits remaining after deducting the profits from the basic activities from the total profits of the related party transactions are divided by the expenses required for the construction of the intangible assets held by both parties Then, it is confirmed whether or not a division factor having a certain reliability can be selected (S26). If the process of S26 is YES, the residual profit split method is left as a candidate (S28).

  When the process of S26 is NO, it is determined that it is necessary to review the transaction content because an appropriate method for calculating the price between independent companies cannot be found (S30).

  As a result of verifying the optimum independent price calculation method in such a procedure, for example, when the example shown in FIGS. 3 and 4 is verified, a finding list as shown in FIG. 5 is obtained. Specifically, it is judged that the independent price comparison method, the resale price base method, and the cost base method are not possible because no comparable transaction can be found.

  In addition, the transaction unit operating income method is considered appropriate because it allows us to find comparable transactions and that the subsidiary does not have any significant intangible assets.

  Although the contribution-to-profit split method is not impossible, it is appropriate because the company does not belong to the oligopolistic market, etc., and it does not carry out activities in which functional risks between parents and children are highly integrated. Judge that it is not good.

  The comparison target transaction is determined to be impossible because the comparison target transaction cannot be found. The residual profit split method is not impossible, but it is not appropriate to say that a subsidiary has significant intangible assets.

  From the above verification, in the example of FIGS. 3 to 5, it is determined that the transaction unit operating profit method with the subsidiary as the verification target is optimal.

  The output unit 16 not only shows a verification list for the optimal transaction price calculation method as shown in FIG. 5, but also for a list of various verifications as shown in FIGS. Show. Accordingly, the person in charge of the company can create a document relating to the transfer price tax system of the company based on each of these lists.

  The moving image distribution unit 14 distributes a moving image for transferring the document creation know-how regarding the transfer price tax system of the company. As described above, when a person in charge of a company prepares a document related to the transfer price tax system of a company based on each list output by the output unit 16, there is a possibility that an unclear point may appear in detail.

  In such a case, for example, by inputting a question item through the input unit 12, an answer to this question is distributed as a video, so that a person in charge of the company performs a follow-up to create a transfer price document. be able to.

  Next, the operation of the transfer price document creation in-house consulting system 10 configured as described above will be described. As mentioned above, in recent years, from the viewpoint of clarifying transfer pricing taxation procedures, the introduction of substantive transfer pricing documentation rules in the tax system revisions has led to large companies operating overseas as well as small and medium-sized enterprises. However, the implementation of transfer pricing documentation is an issue.

  In order to prepare transfer pricing documents, it is often requested to ask specialists such as tax accountants and certified public accountants who are familiar with the transfer pricing tax system, but the outsourcing costs are often high, and there is a large amount of financial resources. Regardless of the company, it is a big burden for small and medium-sized companies.

  However, according to the transfer price document creation in-house consulting system 10, by inputting information about the company via the input unit 12, the functions performed by the parent company and the subsidiary, the risks borne, intangible assets, etc. are verified and listed. Also output as a table. It is also possible to determine the optimum independent price calculation method that is a core part in creating the transfer price document.

  Based on this organized information, the person in charge of the company can prepare a transfer price document even if the person does not have detailed knowledge about the transfer price tax system. In addition, even when there are unclear points when creating a transfer price document based on this information, the answer to this question is distributed as a video by inputting the question content via the input unit 12. Therefore, the person in charge of the company can continue to create transfer price documents by watching this video.

  In this way, even a person in charge of a company who does not have detailed expertise on the transfer pricing taxation system transfers the know-how by using the transfer price document creation in-house consulting system 10, and transfers the transfer price document without outsourcing. There is a remarkable effect that in-house production can be achieved.

10 Transfer price document creation in-house consulting system, 12 input section, 14 video distribution section, 16 output section.

Claims (3)

A transfer pricing document creation in-house consulting system to transfer the document creation know-how regarding the transfer pricing taxation system of a company,
An input unit for inputting information about the company;
An output unit for obtaining and outputting an optimal independent company price calculation method based on the information on the company input by the input unit;
In-house consulting system for creating transfer price documents. In the transfer price document creation in-house consulting system according to claim 1,
A transfer price document creation in-house consulting system further comprising a moving image distribution unit for distributing a moving image for transferring the document creation know-how. In the transfer price document creation in-house consulting system according to claim 1 or claim 2,
The optimal method for calculating the price between independent companies is:
Transfer characterized by one of the independent price ratio method, resale price method, cost method, transaction unit operating profit method, contribution profit split method, comparative profit split method, and residual profit split method In-house consulting system for creating price documents.