Module 3 – CaseTransfer Pricing and Responsibility CentersAssignment OverviewTransfer Pricing In recent years, high-profile cases involving companies like Apple (Ireland, 2016), Amazon (Luxembourg. 20 Original Papers

Module 3 – CaseTransfer Pricing and Responsibility CentersAssignment OverviewTransfer Pricing

In recent years, high-profile cases involving companies like Apple (Ireland, 2016), Amazon (Luxembourg. 2017), and Starbucks (UK, 2012) have highlighted the risks of using aggressive transfer pricing to minimize taxes. These companies faced public backlash and government scrutiny for shifting profits to low-tax jurisdictions, raising questions about their commitment to corporate social responsibility.

Module 3 Case Resources

KPMG article: Worldwide trends in transfer pricing (2024) Transfer pricing controversy trends – Deloitte’s 2024 global survey (2024) Transfer Pricing: What It Is and How It Works, With Examples (2024)Common Challenges to Consider in Transfer Pricing (2024) What Is Cost-Based Transfer Pricing? (2024)The Primary Advantage of Negotiated Transfer Pricing (2024) Transfer Price: How Transfer Price Can Help You Allocate Costs and Profits among Different Units of Your Organization (2024) 

Case AssignmentDefining the Concepts

Using the resources provided:

• Pros and cons of Market-Based Transfer Pricing. Include Tax Implications (1 page)
• Pros and cons of Cost-Plus Transfer Pricing. Include Tax Implications (1 page)
• Pros and cons of Negotiated Transfer Pricing. Include Tax Implications (1 page)

The explanations for each concept must be one page in length and include in-text citations. 

Get Your Data 

You will create a simulation for Case 3 using the free version of ChatGPT which you worked with in Module 1. How to cite ChatGPT  

For Case 3 

• Query 1: Create a simplified transfer pricing simulation to analyze for a global technology company with 3 divisions and 3 country locations.Include: Transfer Pricing Methods: Market-Based Pricing, Cost-Plus Pricing, Negotiated Pricing. Run the Simulation.

Screenshot the query and paste it into a second Word document that must be uploaded with your assignment. A screenshot is different than copying and pasting. Your assignment will not be graded without the screenshots.

How to take screenshots on Windows 11

Take a screenshot on your Mac

Simulation Results

Copy and paste the Overview Table from ChatGPT. 

• Provide an overview of the simulation table outcome from an accounting perspective.
• Based on the research completed in the first section, analyze the simulation. (1 page) Research required.

Ethical Considerations in Transfer Pricing

• Discuss the ethical implications of transfer pricing practices, particularly when companies use them to shift profits to low-tax jurisdictions. Analyze the transfer pricing practices of a high-profile company accused of unethical tax avoidance in the past 18 months. Debate the ethical and corporate social responsibility aspects of their practices and propose alternative strategies that balance tax efficiency with ethical business conduct. (1 page) Research required.

Transfer Pricing and Emerging Technologies (AI, Blockchain)

• Investigate the potential role of emerging technologies like AI and blockchain in automating and improving transfer pricing documentation and compliance. Explore how companies can use AI to predict arm’s length prices or blockchain for transparent documentation in transfer pricing. Discuss the benefits and challenges of adopting these technologies for global businesses. (1 page) Research required.

NOTE: You are not permitted to ask ChatGPT to write the content. If the assignment is written by AI, a zero will be awarded and no resubmission will be accepted. 

Since you are engaging in research, be sure to cite each paragraph and add a reference list in APA format. NOTE: failure to use research with accompanying in-text citations to support content will result in a score of 60% for each grading criterion. This is a research-based, professional paper, not a personal one based on feelings. It must be written in the third person. This means words like “I,” “we,” and “you” are not appropriate. No quotations are permitted in this paper. The excessive use of quotes will directly impact performance since this indicates a lack of comprehension and shows that you may not have mastered the concepts.

Need help with the reference list format or citation format?

• Free Citation Generator (APA)
• “Full citation” is for the Reference list. In-text citation is used in the written paragraph.

Assignment Expectations

Use the ACC501 Case 3 APA-formatted template to create your submission.

• The template is set up in APA 7: double-spacing, font, margins, headings, page breaks, APA help links.

Your submission will include:

• Trident University International’s cover page
• A paper with APA citations (2- to 3-sentence Overview, 6-page body, 2- to 3-sentence conclusion) Page counts do not include content, data, tables, or graphs from ChatGPT.
• The reference list page in APA format
• A Word file containing screenshots from ChatGPT. The assignment will not be graded unless this is submitted.