Definition
In
this method, the total price of intangible incurred by the tested parties in
transferring products and services to Associated Enterprises is measured and
the sum of gross profit spot used by similar enterprises in comparable
transactions with self-determining associated enterprises is determined. The
sum of gross spot arrived at is used to take into account functional and other
variation to determine ALP. The extra similarities in the functions, risks and
property, the extra likely it is that the cost plus method will create an
suitable estimation of an arm's length result. This
method is generally used where semi finished products are transferred.
In
common, for reason of apply a cost-based method, costs are divided into three
categories:
Direct
costs:- raw materials;
Indirect
costs:- repair and maintenance which may be allot among several goods.
Operating
expenses:- selling, general, and organizational expenses.
The
cost plus method uses limits calculated after direct and indirect costs of
goods. Correctly shaping cost under the cost plus method is important. Cost is
typically calculated in agreement with accounting values that are usually
accepted for that exacting industry in the region where the products are
produced.
The
cost base of the deal of the associated parties to which a mark-up is to be
applied be calculated in the same way and returns comparable functions, risks,
and properties as the cost base of the similar transactions. Where cost is not
exactly resolute in the same way, both the mark-up and the transfer will be
used.
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