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Minggu, 06 Mei 2012

Financial Risk, TRANSFER PRICING AND TAXATION INTERNATIONAL


FINANCIAL RISK MANAGEMENT

Main Components of Foreign Currency Risk
a.       Accounting risk (the risk of accounting): The risk that the preferred accounting treatment of a transaction are not available.
b.      Balance sheet hedge (balance sheet hedging): Reducing foreign exchange exposure faced by differentiating the various assets and liabilities of a company abroad.
c.        Counterparty (the opponent): Individuals / organizations who are affected by a transaction.
d.      Credit risk (credit risk): The risk that the opponent had failed to pay its obligations.
e.       Derivatives: the contractual agreement creating rights or obligations specific to the value derived from other financial instrument or commodity.
f.        Economic exposure (economic exposure): Effect of changes in foreign exchange rates against the cost and revenue in the future.
g.      Exposure management (exposure management): Preparation of the corporate structure to minimize the adverse effect of exchange rate changes on earnings.
h.      Foreign currency commitment (commitment to a foreign currency): Commitment to the sale / purchase of the company denominated in foreign currencies.
i.        Inflation differential (difference of inflation): The difference in the rate of inflation between two countries or more.
j.        Liquidity risk (liquidity risk): The inability to trade a financial instrument in a timely manner.
k.      Market discontinuities (discontinuities market): Changes in market value suddenly and significantly.
l.        Market risk (market risk): risk of losses due to unexpected changes in foreign exchange rates, commodity loans, and equity.
m.   Net exposed asset position (the net asset position of the potential risk): Excess assets position of the position of liabilities (also referred to as a positive position).
n.      Exposed net liability position (potential risk of the net liability position): Excess liability position to the position of the asset (also referred to as a negative position).
o.      Net investment (net investment): An asset or net liability position that happens to a company.
p.      National amount (national number): Total principal amount stated in the contract to determine the settlement.
q.      Operational hedge (hedging operations): foreign exchange risk Protection that focuses on variables that affect a company's revenues and expenses in foreign currency.
r.       Option (option): The right (not obligation) to buy or sell a financial contract at a specified price before or during a specific date in the future
s.        Regulatory risk (regulatory risk): The risk that a law limiting the public will mean the use of a financial product.
t.       Risk mapping (risk mapping): Observing the temporal relationship with the market risks of financial reporting variables that affect the value of the company and analyze the possibility of occurrence.
u.      Structural hedges (hedge structural): Selection or relocation of operations to reduce the overall foreign exchange exposure of a company.
v.       Tax risk (the risk of tax): The risk that the absence of the desired tax treatment.
w.     Translation exposure (translation exposure): Measuring the effect in the currency of the parent company of the change in foreign exchange for the assets, liabilities, revenues, and expenses in foreign currencies.
x.       Transaction risk potential (the potential risks of the transaction): Foreign exchange gains or losses arising from the settlement or conversion of  foreign currency transactions.
y.      Value at risk (the value of the risk): Risk of loss on trading portfolio of a company which is caused by changes in market conditions.
z.       Value drivers (trigger value): The accounts of the balance sheet and income statement which affects value of the company.

Duties Manage Risk In Foreign Currency
The growth of risk management services that quickly shows that management can enhance shareholder value by controlling the financial risk. If the value of the company to match the present value of future cash flows, active management of potential risks can be justified by several reasons.
Exposure management helped in stabilizing the company's cash flow expectations. Flow is more stable cash flows that can minimize earnings surprises thus increasing the present value of expected cash flows. Active exposure management allows companies to concentrate on the major business risks.
Lenders, employees and customers also benefit from exposure management. Finally, because of losses caused by price and interest rate risk of certain transferred to the customer in the form of higher prices, limiting exposure management of risks faced by consumers.

Calculating the Risk of Translation
The process of re-presentation of financial information from one currency to another currency is called translation. Translation is not equal to the conversion.
Conversion is the exchange of one currency to another currency physically. Translation is just a change of monetary units, such as only a balance sheet re-expressed in GBP are presented in U.S. dollar equivalent value. Potential risk of these measuring translational effects of changes in foreign exchange against domestic currency equivalent value of assets and liabilities denominated in foreign currency held by the company.
Translational gauge potential risk of exchange rate changes impact on the domestic currency equivalent value of assets and liabilities denominated in foreign currency held by the company. Because the amount of foreign currency is generally translated into domestic currency equivalent value for purposes of monitoring or management of external financial reporting, translational effects that pose an immediate impact on the desired profit. Excess of assets exposed to liability risk exposure (ie items in foreign currencies are translated based on the present exchange rate) led to the position of net assets are exposed. This position is often called the potential positive risks. Devaluation of foreign currencies relative to the reporting currency translation losses caused. Revaluation of foreign currency translation profits. Conversely, if the company has a net liability position or potential exposure to downside risk if liabilities exceed assets exposed exposed. In this case, the devaluation of foreign currency translation gains cause. Revaluation of foreign currency translation losses caused.

Calculating Risk Transactions
Potential risk of the transaction, gains and losses related to foreign exchange rates arising from the settlement of transactions denominated in foreign currencies. Transaction gains and losses have a direct impact on cash flow. Potential risks of the transaction report contains items that generally do not appear in conventional financial statements, but it raises transaction gains and losses as foreign currency forward contracts, purchase commitments and future sales and long-term lease.
To minimize or eliminate the potential risks, it takes a strategy that includes the balance sheet hedging, operational, and contractual. Balance sheet hedging can reduce the potential risks facing the company by adjusting the level and value-denominated monetary assets and liabilities are exposed. Focusing on operational hedging variables affecting revenues and expenses in foreign currencies. Structural hedging include relocation of manufacturing to reduce the potential risks facing the company or changing the State which is a source of raw materials and component manufacturing. Contractual hedging was developed to provide greater flexibility for managers to manage the potential risks faced by foreign exchange.

The risk difference of Accounting and Economic Risk
Differences in the basic financial instrument such as repurchase agreements (accounts), bonds, and capital stock, meet the definition of conventional accounting for assets, liabilities, and owner's equity While the derivative instruments are contractual agreements that give special rights or obligations and obtain the value of financial instruments or commodities other.
In our opinion, the difference lies in a different perspective because of reports of potential risks in light of the translation of the parent company.
Forward exchange contract is a contract between two parties to exchange a certain amount of currency with another currency at a certain date in the future. While the futures contract is an exchange-traded contracts that specify delivery of a specific currency at a date that has been ensured in the future.
Because when we handle the design of a program to hedge the market  risks faced by customers and how we handle it, and it requires a lot of knowledge about accounting management accounting in particular.
Actively hedge against the potential financial risks are not generally accepted among financial managers around the world. Some argue that financial management alone will not able to increase the value of the company and that company better manage its core business risks and allowed himself to be exposed by some (if not, all) financial risk.

Protection Strategy Exchange Rate and Accounting Treatment of the required
After identifying potential risks, the next is designing hedging strategies to minimize or even eliminate the potential risk. This can be done with balance sheet hedging, operational, and contractual.
a.              Balance Sheet Hedging
Protection strategy by adjusting the level and value of monetary assets and liabilities denominated exposed companies, which will reduce the potential risks facing the company. Example of a hedging method subsidiaries located in countries that are vulnerable to devaluation is:
·                Maintain cash balances in local currency at the minimum level needed to support current operations.
·                Restore the earnings above the amount required for expansion capital to the parent company.
·             Speeding (ensure-leading) the receipt of outstanding trade receivables denominated in local currency.
·                Delay (slow-lagging) the payment of debt in local currency.
·                Accelerate the payment of debts in foreign currencies.
·                Invest surplus cash into the stock of debt assets of other funds in local currency which was less affected by devaluation losses.
·                Invest in assets outside the country with a strong currency.
b.             Operational Hedging
Focusing on operational hedging variables affecting revenues and expenses in foreign currencies. More stringent cost control allows a greater margin of safety against potential currency losses. Structural hedging include relocation of manufacturing to reduce the potential risks facing the company or changing the state is the source of raw materials and component manufacturing.
c.              Contractual Hedging
One form of hedging with financial instruments, both the derivative instrument and the basic instrument. This instrument products include forward contracts, futures, options, and the mix of all three are developed. To provide greater flexibility for managers to manage the potential risks faced by foreign exchange.

Accounting and Control Problems, related to Risk Management Foreign Exchange
Examples of accounting and control issues associated with the risk management of foreign exchange can be seen in the following cases:
These companies continuously create and implement new strategies to improve their cash flow in order to increase shareholder wealth. It does require some expansion strategy in the local market. Other strategies require penetration into foreign markets. Foreign markets can be very different from the local market. Foreign markets creates opportunities increased incidence of corporate cash flow.
The number of barriers to entry into foreign markets that have been revoked or reduced, encouraging companies to expand international trade. Consequently, many national companies become multinational companies (multinational corporation) that are defined as companies engaged in some form of international business.
MNC own purpose generally is to maximize shareholder wealth. Goal setting is very important for an MNC, as all decisions must be made ​​to contribute to the achievement of these goals. Any corporate policy proposals not only need to consider the potential return, but also its risks. An MNC must make decisions based on the same goal with the goal of purely domestic firms. But on the other hand, MNC companies have a much wider opportunity, which makes the decision became more complex.
There are several constraints faced by MNC companies such as, environmental constraints, regulatory constraints, and ethical constraints. Environmental constraints can be seen from the different characteristics of each country. Regulatory constraints of each country regulatory differences that exist such as, taxes, currency conversion rules, as well as other regulations that may affect the cash flows of subsidiaries. Constraint itself is described as an ethical business practices vary in each country.
MNC, in doing international business, in general can use the following methods:
o   International trade
o   Licensing
o   Franchising
o   The joint venture
o   Acquisition of companies
o   Establishment of new subsidiaries abroad
International business methods require direct investments in operations abroad, or better known as the Direct Foreign Investment (DFI). International trade and licensing is usually not considered a DFI because they do not involve direct investment in overseas operations. Franchising and joint ventures tend to ask for direct investment, but in relatively small amounts. The acquisition and establishment of new subsidiary is the largest element of DFI.
Various opportunities and advantages of a MNC is not free from risks that would arise. Although international business can reduce the exposure of an MNC to the economic conditions of their home country, international business usually also increase the MNC's exposure to exchange rate movements, economic conditions abroad, and political risk. The businesses Sebagian exchange of one currency International is calling others to the currency of payment. Because the exchange rate continues to fluctuate, the amount of cash required to make payments is also uncertain. Consequently, the number of currency units of country of origin is required to pay may change even if its suppliers do not change the price. In addition, when multinationals enter foreign markets to sell products, the demand for such products depends on economic conditions in those markets. Thus, the multinational company's cash flow is affected by economic conditions overseas.
Management can use the controls on foreign currency exchange rates by hedging. However, any financial risk management strategy should evaluate the effectiveness of the hedging program. Feedback from the evaluation system that is running will help to develop the institutional experience in the practice of risk menajamen. Performance assessment of risk management program also provides information about when the current strategy is no longer appropriate to use. So basically, effective financial control is a system of performance evaluation.
In many organizations, foreign exchange risk management is centralized at corporate headquarters. This allows the managers of subsidiaries to concentrate on its core business. However, when comparing the actual and expected results, the evaluation system must have a reference that is used to compare the  success of the company's risk protection.


TRANSFER PRICING AND TAXATION INTERNATIONAL

Basic Concepts of International Taxation
The complexity of the laws and rules that determine the tax for foreign companies and the profits generated abroad actually derived from some basic concepts:
a.         Tax neutrality is that the tax has no effect (or neutral) of the resource allocation decisions.
b.        Tax equity is that taxpayers who are facing similar situations should pay similar taxes and the same thing but on disagreements between how to implement this concept.

With the use of tax Profit From Foreign Sources
Each country claims the right to impose taxes on income generated within its borders. However, the national philosophy on the taxation of resources from abroad is different and this is important from the perspective of a tax planner. Most countries (including Australia, Brazil, China, Czech Republic, Germany, Japan, Mexico, Netherlands, United Kingdom, and United States) to apply the principles throughout the world and impose taxes on profits or income of the company and the citizens in it without looking at the territory of the State. The underlying idea is that a foreign subsidiary of a local company is a local company that happens to operate overseas.

Foreign Tax Credit
Foreign tax credit can be counted as a direct credit on income tax paid on earnings branch or subsidiary and any tax withheld at source such as dividends, interest, and royalties are sent back to domestic investors. The tax credit can also estimated if the amount of foreign income tax paid is not too clear.
Tax Credit Restrictions
Foreign tax credit limitation applies separately to U.S. tax on foreign source income tax for each of the following types of income:
1.       passive income
2.      Financial services revenue
3.      Income levy high taxes
4.      transportation revenue
5.      Dividend for each of the foreign company with a share of ownership by 10% to 50%.
Tax treaty
Tax treaties affect the tax levy on dividends, interest and royalties paid by companies in the country to foreign shareholders. These agreements typically provide a reciprocal reduction of tax levies on dividends and royalties are often exempt from taxes and interest charges.

International Tax Planning in Multinational Corporations
At the time of the tax planning of multinational companies have certain advantages over a purely domestic firm because it has a greater geographic flexibility in determining the location of production and distribution systems. This flexibility would give opportunity to utilize a separate juridical differences between national tax  so as to lower the overall corporate tax burden.
The observation of these tax planning issues at the start with two basic things:
a.       Tax considerations should never mengandalikan business strategy
b.      Constant changes in tax laws limit the benefits of tax planning in the long term.

Variables in International Transfer Pricing
Transfer prices set a monetary value on the exchange between firms that take place between the operating unit and is a substitute for market prices. Often the transfer price is recorded as revenue by one unit and the unit cost by others. Cross-border transactions of multinational corporations are also open to a number of environmental influences that created the same time destroying the opportunity to increase profits through transfer pricing. A number of variables in the transfer pricing separti tax rate competition infalsi rates, currency values​​, limitations on the transfer of funds, political risk and the interests of joint venture partners are very complicated transfer pricing decisions.

Transfer Pricing
Set prices on barangĂș and services transferred between corporations within a group for the purpose of minimizing the overall corporate tax.
for example:
-               Establish a high transfer price at which the components are shipped from the subcontractor in countries with relatively low tax rates.
-               On high transfer price at which the components are shipped from the subsidiary in the country which is relatively high tax rates.
Factors underlying the Establishment of Policy D (Methods) TRANSFER PRICING:
a.              Size (size of the company).
Large companies tend to use market-based transfer pricing policy
b.             Organizational Design (design organization)
Centralized operations, then the transfer price set center manager. Instead of decentralization gives maximum autonomy to the manager of the subunits in transfer pricing.
c.              Degree of International Movement (the level of international involvement)
Transfer pricing in multinational companies is more influenced by environmental considerations.
d.             Cultural influences (cultural influences)
U.S. companies, Canada, France and Italy as the main factors to consider tax rates that affect the transfer. The Japanese company is considering the environmental effects (such as inflation and currency revaluation) than U.S. firms.
e.       Legal obligations
prevent conflicts dg taxation officials, government antitrust authorities and market regulators in both the home or host country.





sources:
Choi, Frederick D.S., and Gerhard D. Mueller, 2005., Akuntansi Internasional – Buku 1, Edisi 5., Salemba Empat, Jakarta.
Choi, Frederick D.S., and Gerhard D. Mueller, 2005., Akuntansi Internasional – Buku 2, Edisi 5., Salemba Empat, Jakarta.