4 Challenges Of Transfer Pricing For Tangible Assets

Transfer pricing refers to the practice of pricing goods and services that are traded between related entities within the same multinational group. Transfer pricing is often used as a tax planning tool for multinational corporations, as it allows them to allocate profits to jurisdictions with more favourable tax rates. While transfer pricing is a common practice for all types of goods and services, it presents unique challenges for tangible goods.

In this article, we will discuss the challenges of transfer pricing for tangible goods.

1. Determining the appropriate transfer price

The first challenge of transfer pricing for tangible goods is determining the appropriate transfer price. Unlike intangible assets or services, tangible goods are physical items that can be inspected and measured. However, determining the value of a tangible good is not always straightforward. Various factors, such as quality, design, and market demand, can influence the price. Additionally, raw material prices and labour costs can vary significantly between countries, adding complexity to the transfer pricing process.

To determine the appropriate transfer price for tangible goods, multinational corporations must consider a range of factors, including the costs of production, market prices, and the prices of comparable goods. This can be a complex process and requires a thorough understanding of the market and the value of the goods being traded.

2. Complying with transfer pricing regulations

Another challenge for multinational corporations when dealing with tangible goods is complying with transfer pricing regulations. The transfer pricing regulations vary between countries and can be complex. The OECD guidelines on transfer pricing provide a framework for multinational corporations to ensure that their transfer pricing practices are compliant. However, even with the guidelines, transfer pricing regulations can be difficult to navigate, especially when dealing with tangible goods.

Multinational corporations must ensure that they comply with the transfer pricing regulations in each country where they operate. Failure to comply can result in fines, penalties, and reputational damage. Thus, multinational corporations need to work with transfer pricing experts to ensure compliance with the regulations.

3. Data and documentation requirements

Multinational corporations dealing with tangible goods face a significant challenge when it comes to data and documentation requirements. They must keep detailed records of their transfer pricing practices, including how they arrived at the transfer price for each transaction. Documentation requirements can vary between countries, but the OECD guidelines recommend that multinational corporations maintain transfer pricing documentation that outlines their transfer pricing policies, the factors they considered when determining transfer prices, and the results of their transfer pricing analysis.

This documentation can be a challenge for multinational corporations dealing with tangible goods as it requires detailed data on production costs, market prices, and other factors that influence the transfer price. It can also be difficult to maintain accurate records when dealing with large volumes of transactions. Nonetheless, multinational corporations must ensure that they maintain comprehensive documentation to comply with transfer pricing regulations.

4. Managing transfer pricing risk

Transfer pricing is a high-risk area for multinational corporations, as it is subject to intense scrutiny from tax authorities around the world. Even minor errors in transfer pricing arrangements can result in significant penalties and reputational damage.

To manage transfer pricing risk, multinational corporations must adopt a proactive approach that regularly monitors and reviews their transfer pricing arrangements. This may involve engaging external advisors to conduct transfer pricing risk assessments and regularly training employees on transfer pricing compliance.


Transfer pricing for tangible goods presents unique challenges that multinational corporations must navigate. Therefore, multinational corporations must work with transfer pricing experts to ensure compliance and adopt a proactive approach to managing transfer pricing risk effectively. Overall, it is crucial to thoroughly understand the market and the value of the goods being traded to address these challenges.

Max Lewis provides an array of services ranging from Employee Shares Option Plan in Singapore to international tax planning and GST Assisted Self-Help Kit. We are a proud recipient of the Best Transfer Pricing Consultancy Firm of the Year at Corporate LiveWire Global Awards and the Best Transfer Pricing Advisory Specialists – Singapore award at APAC Insider Southeast Asia Business Awards 2022. These awards proved our ability to produce remarkable results while exhibiting exceptional business performance. Do not hesitate to reach out to us today for more information about our various services.

*The above represents our opinions and views and does not reflect the position of any entities mentioned.