Question

I have a client, XYZ company. XYZ has 2 foreign subsidiaries, ERT in Mexico and TRE in Canada. XYZ company is located in USA. XYZ company males automobile parts for the major automobile companies in North America. USA assemblies automobile finished parts for a car. ERT makes labor intensive parts such as wire harnesses and plastic parts plus brake pad parts. TRE Canada males aluminum engine parts that are assembled in Mexico --the engine. All finished parts are finally send to US automobile assembly plants in Ohio, Wisconsin, Illinois, and Tennessee. The XYZ company tax bracket is 20%. TRE Canada has a 12% tax bracket. ERT Mexico has a 8% tax bracket. What might be one tax strategy that XYZ company may implement for the Company? With Mexico and Canada?

Answer 1

XYZ company can follow a strategy which increases its cost in Canada, as Canada's tax rate is more then Mexico and thus it can show higher revenues in Mexico by inter-company transactions. Many international companies take advantage of inter-company transfer pricing and other related party transactions to influence IC-DISC, promote improved inter-company transaction taxes, and effectively enhance efficiency within the company. Inter--company transactions can be essential to maximizing the allocation of income and deductions.