Traduction de «Marge du coût de revient majoré » (Français → Anglais) :

29. Notes that the existing guidelines for transfer pricing leave MNCs a significant margin of discretion in the choice and implementation of evaluation methods; stresses that the lack of any effective common standard for transfer pricing and the various derogations, exceptions and alternatives provided for are being exploited by MNCs, in contradiction with the spirit of those guidelines, to calibrate their taxable profits by jurisdiction and reduce their overall tax liability through, for instance, abusive cost-plus, arbitrary setting of profit margins or the questionable exclusion of certain expenditure from their calculation; stress ...[+++]es that the best way to address the issue of transfer pricing at EU level is through common tax base consolidation, which does away with the need for these prices;

‘full cost’ means the cost of providing service plus a reasonable charge for administrative overhead.

3. When there are no or insufficient sales of the like product in the ordinary course of trade, or where because of the particular market situation such sales do not permit a proper comparison, the normal value of the like product shall be calculated on the basis of the cost of production in the country of origin plus a reasonable amount for selling, general and administrative costs and for profits, or on the basis of the export prices, in the ordinary course of trade, to an appropriate third country, provided that those prices are re ...[+++]presentative.

A cost-plus mark-up is added to these costs to obtain an appropriate profit in the light of the functions performed, assets used, risks assumed and market conditions.

In some areas of agricultural activity, such as bee production, EU support represents the profit margin which in effect means consumers enjoy a quality food product at production costs and regretfully, as demonstrated in recent years, sometimes below the cost of production.

Studies have also been carried out to investigate the relationship between the normal price, which is the full cost of production plus a profit margin of 5%, and the actual contract price charged by certain Korean shipyards.