Question

Trans Atlantic Metals has two operating divisions. Its forging operation in Finland forges raw metal, cuts it, and then ships it to the United States where the company’s Gear Division uses the metal to produce finished gears. Operating expenses amount to $22.0 million in Finland and $62.0 million in the United States exclusive of the costs of any goods transferred from Finland. Revenues in the United States are $170 million. If the metal were purchased from one of the company’s U.S. forging divisions, the costs would be $32.0 million. However, if it had been purchased from an independent Finnish supplier, the cost would be $42.0 million.

The marginal income tax rate is 70 percent in Finland and 30 percent in the United States What is the company’s total tax liability to both jurisdictions for each of the two alternative transfer pricing scenarios ($32.0 million and $42.0 million)? (Enter your answers in dollars and not in millions of dollars.)

Answer 1

If the transfer price is $32 million, the tax liabilities are
	Finland	USA
Revenue	$32,000,000.00	$170,000,000.00
Third-party costs	$22,000,000.00	$32,000,000.00
Transferred goods costs		$32,000,000.00
Total costs	$22,000,000.00	$64,000,000.00
Taxable income	$10,000,000.00	$106,000,000.00
Tax rate	70.00%	30.00%
Tax liability	$7,000,000.00	$31,800,000.00
Total Tax liability	$38,800,000.00
If the transfer price is $42 million, the tax liabilities are
	Finland	USA
Revenue	$42,000,000.00	$170,000,000.00
Third-party costs	$22,000,000.00	$32,000,000.00
Transferred goods costs		$42,000,000.00
Total costs	$22,000,000.00	$74,000,000.00
Taxable income	$20,000,000.00	$96,000,000.00
Tax rate	70.00%	30.00%
Tax liability	$14,000,000.00	$28,800,000.00
Total Tax liability	$42,800,000.00
The total tax liability is higher if profits are shifted to the country with the higher tax rate.