The Transfer Pricing Problem in a Service Firm : A Case Study on a Swedish Multinational Enterprise

Abstract: The purpose of this study is to answer the research question of how a service company (ServiceCo) could achieve a transfer price of its services. This is of particular interest, due to the growth of service firms that have rapidly increased and surpassed the manufacturing firms, as well as the dominant logic shifting towards services. However, the problem with this field of study is that transfer pricing with regards to the service industry, is a rather unexplored phenomenon in which the guidelines and theories are mostly directed towards manufacturing firms. This study uses a single case study approach where ServiceCo’s organizational characteristics were analyzed in order to attain the information required to understand how ServiceCo could achieve a transfer price of its services. Furthermore, this study uses the Eccles (1983) MAP and the OECD Guidelines, as well as incorporating Porter’s (1985) value chain. This study assesses that ServiceCo, in its current state, uses a sub-optimal transfer pricing method of its services. Therefore, a change in the transfer pricing method was suggested to ServiceCo. Given the organizational characteristics of ServiceCo, the results led to the conclusion that ServiceCo could benefit from a residual analysis in the profit split method, in which an actual full cost plus mark-up compensation could be used on its routine functions, and the residual profit could be split between the entities based on the intangible assets employed, functions performed and the risks carried.