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An example of profit division method
Company A in country A and Company B in country B are affiliated enterprises. The operating assets of Company A are $50 million, while that of Company B is $654.38+$50 million. The sales cost of Company A is $6,543,800+million, and the operating profit is $2 million. Company B's operating profit for this period is $3 million. Now country A should determine the reasonable selling price of company A to company B according to the profit division method, and take the scale of operating assets as the only parameter to measure the contribution to profits.

Since the ratio of operating assets of Company A and Company B is 1:3, their respective profit ratios should also be 1:3. In this way, the profit of Company A should account for a quarter of the five million total profits of the two companies, that is, 1.25 million dollars, while the profit of Company B should be 3.75 million dollars. Since the sales cost of Company A is100000 USD, its reasonable sales price to Company B should be11250000 USD. Company A in country A is a pharmaceutical company, which owns the trademark rights of two drugs. Company A transfers the trademark use right and drug processing right of drugs to subsidiary B of country B, and all drugs produced by company B are sold to company A, and then company A sells drugs in country A. The tax authorities of country A share profits by profit division method, and the functions played by companies A and B are divided into four categories, namely sales, processing and manufacturing intangible assets and manufacturing intangible assets.

The tax department determines the profit of sales and manufacturing functions according to the cost plus 100% price increase; After deducting the sales and manufacturing profits from the total profits of Company A and Company B, the remaining profits will be divided into the function of manufacturing intangible assets owned by Company B and the function of selling intangible assets owned by Company A according to 55%.