Transfer pricing in banks download materials. Transfer pricing

In Belarusian business there are different schemes for building a business. It has become standard to build a network of subsidiaries with the same type of activity and preferential terms of activity, for example, using the simplified tax system, in small towns, individual entrepreneurs, residents of FEZ and HTP. The founders and managers of such companies are wives, children, brothers and sisters, other relatives and other controlled persons. In such cases, companies sell each other a product or service at a better price or at a price different from the market price, which allows them to redistribute their overall profits and pay taxes on them at lower rates or not at all.

The newly introduced rules of the Tax Code in the field of transfer pricing, with a healthy desire to pay less taxes, oblige taxpayers to act within the established rules. The desire to “go around” or not to comply (maybe they won’t find it) can be fraught with serious financial losses for the business.

There are 2 companies A (applies a general taxation system) and B (applies a simplified taxation system). In company A the founders are Petrov and Sidorova, and in company B the founders are the wives of Petrov and Sidorov. Company A imports a product and sells it at a minimum margin below the market price of more than 20% to Company B. Company A receives minimal revenue and loss, but does not pay income tax. A Company B sells goods at market prices and pays 5% on turnover. Thus, company A pays minimal value added and profit taxes, and company B, using a simplified taxation system, pays minimal tax on revenue. In light of the new transfer pricing approach, Company A's profits will be increased by the amount of revenue as if the goods were sold at market prices, and income tax will be increased.

Citizen A is the founder of OJSC T with a 45% share and a member of the supervisory board of the named company. At the same time, he is the founder and director of P LLC. OJSC "T" purchases materials from LLC "P" for the manufacture of products at prices different from the market value + 20%, that is, more expensive. OJSC “T” minimizes profit tax due to inflated costs for materials. Keep in mind that such expenses in the event of a tax audit may be excluded from expenses and additional income tax will be charged.

The situations given are examples of transfer pricing (general part of the Tax Code, Article 20). As you understand, there are a great many such examples. And a simple attempt to save money leads to significant losses and problems.

Transfer pricing is the sale of various services or goods by interdependent parties, which is carried out at prices different from market prices. Using transfer pricing, organizations minimize taxes. And this must be done in such a way as not to violate legal requirements, on the one hand, and not to entail additional financial losses and penalties from the tax inspectorate, on the other hand.

Transfer pricing came to us in 2012. In the period from 2012 to 2014, only transactions for the sale of real estate and the sale of goods to foreign legal entities and (or) individuals as part of foreign trade activities were under control. Since 2015, the list of controlled transactions has been expanded to include objects of control in the form of work performed and services provided within the framework of foreign economic activity.

Since 2016, transfer pricing has covered almost all areas of economic activity, both foreign economic and on the national market, and not only for the sale of goods, works, services, but also other property and property rights, as well as transactions with related parties.

The concept of interdependent persons is an innovation for the 2016 Tax Code.

Interdependent persons are individuals and (or) organizations, the existence of relationships between which has a direct impact on the conditions or economic results of their activities or the activities of the persons they represent. To put it simply, these are relationships:

1. between persons who are founders (participants) of one organization;

2. when one person acts as a founder (participant) of another organization, if the share of his direct and (or) indirect participation is at least 20 percent;

3. when one person is subordinate to another by official position or one person is (directly or indirectly) under the control of another person;

4. between organizations, if one person directly and (or) indirectly participates in these organizations and the share of such participation in each of these organizations is at least 20 percent;

5. when individuals are, in accordance with the law, in a marriage relationship, a relationship of close kinship or property, an adoptive parent and an adopted child, as well as a guardian, trustee and ward;

6. between the trustor, the trustee and the beneficiary, as well as the trustee and organizations whose property is managed by the trustee;

7. between organizations, in the collegial executive body or board of directors (supervisory board) of which more than 50 percent are the same individuals together with interdependent persons specified in paragraph 4 of this paragraph.

The concept of interdependent persons is present only in tax legislation and only for tax legal relations.

· For example, the following situations may be typical when transfer pricing arises:

1. If you are not the founder of the company, but give instructions to the director to carry out transactions;

2. If you sell your property to a leasing company and then rent it at a price different from the market price +/- 20%;

3. If you are an importer, and your supplier supplies you with goods at prices different from market prices;

4. If one holding company supplies another holding company with raw materials at a price below market

5. and other situations.

· Since 2016, all business entities must:

1. Provide information about interdependent persons and transactions with such persons;

2. Submit information about major transactions to the Ministry of Taxes and provide data on them justifying the transaction price;

3. Prepare a package of documents on the economic justification of prices for transactions with related parties.

Who will the auditors come to first?

· To enterprises that have been unprofitable for several years (two or more years) in a row;

· Part of international companies (i.e. having interdependent organizations abroad);

· Reflecting an insignificant amount of profit with significant volumes of goods sold for two or more years in a row (if such a ratio is not due to the industry characteristics of the payer’s activities);

· To organizations whose level of profitability is below the industry average, based on Belstat information on this type of activity for the corresponding tax period;

· To interdependent persons selling real estate;

· To those carrying out foreign trade activities with a foreign counterparty, if there are signs of interdependence with it, and also if such counterparty has a permanent location in a country (territory) with a level of profit taxation lower than in the Republic of Belarus, is a resident of free (special) economic zones, on territories of which there is a preferential tax regime, etc.

· Which transactions are subject to control?

In 2016, three types of transactions fall under the control of transfer pricing:

1. Transactions with real estate (sales or acquisition), including through housing bonds, shared construction.

2. Foreign trade transactions in the event that the amount of the price of transactions for the sale or purchase of goods (work, services) during one tax period with one person exceeds 1 billion Belarusian rubles, excluding indirect taxes, made with:

With an interdependent person;

With a person whose location (residence) is in an offshore state;

With an interdependent person or with a resident of an offshore zone completed with the participation (intermediation) of a third party (persons) through a set of transactions, provided that such a third party is not interdependent, does not perform any additional functions in this transaction, and does not participate in this transaction in any way assets;

If during the tax period the amount of the price of transactions with one person exceeds 10 billion Belarusian rubles (excluding indirect taxes):

For the sale and (or) acquisition of goods according to the list of strategic goods determined by the Government of the Republic of Belarus (this list has not currently been developed);

For the sale and (or) acquisition of goods (work, services) by organizations included in the list of large payers.

3. Transactions made on the territory of the Republic of Belarus, when the amount of transactions during one tax period with one person exceeds 1 billion Belarusian rubles excluding indirect taxes with an interdependent person - a tax resident of the Republic of Belarus (intermediary) using special tax regimes, registered in the HTP or SEZ, and (or) does not calculate or pay tax (exempt from tax) on profit in the tax period in which the transaction was made.

· Who is responsible for transfer pricing?

There is a stereotype that in an organization the chief accountant is responsible for everything related to pricing and tax calculation. In fact, the director is responsible for organizing transfer pricing work. Performers are specialists who directly carry out the purchase and sale of goods, works, and services. The chief accountant only collects information, submits reports on it, and takes it into account when calculating income tax.

Attention should be paid to the fact that information on transfer pricing will be submitted to the tax authorities through marks on electronic invoices, which will come into effect from July 1, 2016.

If the tax authorities “like” your deal, they have the right to request all documentation confirming the economic justification of the price applied by the payer.

The procedure for monitoring transfer pricing by tax authorities is not yet clear; the practice will be developed. It is advisable, in order to avoid becoming “cats to be trained on,” to begin work now on organizing documentary support for the transactions being made. And the first thing to do is make a list of interdependent persons.

Transfer pricing was developed by Western banks as a method of dividing the price pie into appropriate layers. This made it possible to assess whether the interest margin on active divisions is sufficient to cover their costs, whether there is enough interest income for resource divisions to finance their expenses, and how well the treasury regulates interest rate risk in the bank.

Transfer prices are the prices for funds transferred within a bank from one organizational unit to another. Let's imagine a bank as its headquarters plus three organizational units:

1) a retail bank, which serves, among other things, as a source of funds;

2) a wholesale unit, which serves, among other things, as a user of funds;

3) the treasury, which performs the functions of concluding transactions, which serves as an intra-bank intermediary and is capable of centrally managing risk (see Fig. 3).

One of the treasury functions is to borrow funds from a retail bank and lend them to a wholesale bank. Since the retail bank has greater access to core deposits, it is a suitable source of funds for the wholesale unit.

The problem of assessing intra-company turnover lies in the correct and optimal allocation of costs to deposits. Financial theory suggests that the transfer price should be equal to the retail interest rate for similar securities (identical in risk and term) as deposits. If the price for an intrabank transfer is incorrectly determined, then the retail bank may appear more profitable than the wholesale bank, or vice versa. The correct internal price determines whether funds are directed to a retail or wholesale bank.

Transfer prices make it possible to determine which organizational units contribute to increasing the value of the bank, and which destroy it.

There are several approaches to the formation of transfer pricing. The traditional approach assumes that:

1. The transfer price is determined for each account at the time the account is opened and remains unchanged until it is closed.

2. The transfer price for attraction centers is equal to the cost of alternative resource replacement on the open interbank market for a given period.

3. The transfer price for placement centers is equal to the sum of the transfer price for attraction centers and the spread established by the financing center (treasury) as a fee for interest rate risk.

4. All risks of changes in the transfer price during the investment period are assumed by the financing center (treasury).

This approach presupposes the existence of a powerful analytical system for managing the risks of imbalance of assets and liabilities by maturity, that is, liquidity risks and interest rate risk. In addition, in order to insure against interest rate risk, the treasury must actively work both with instruments of the derivatives market and the real interbank market.

When a bank chooses a classic transfer pricing model, risks accumulate in one department - the treasury, which bears the entire burden of responsibility for market risk. The Treasury receives bonuses for successfully completed work that exceed the income of the resource divisions and asset operations divisions. At the same time, the influence of the market on the income of the latter divisions is reduced to zero, their payment is stable and not subject to serious fluctuations. Despite the external attractiveness of this scheme, there is a significant drawback in the complexity of its implementation associated with the construction of a system for calculating interest risks for each specific asset and liability.

The second transfer pricing option assumes a unified transfer price for resource and active divisions of the bank. In this case, the Treasury (or another structure) does not receive income from intermediary functions; it only regulates intrabank flows; the services of this unit are paid for as services of the management center. This is one of the examples of organizing the work of banks, the basis of which is the principle of a common fund of funds.

This transfer pricing option is the easiest to implement. Risk management here is taken outside the boundaries of the transfer pricing contour and transferred to a specialized unit - the risk management department. In this case, the Treasury can only ensure the coordination of financial flows between various divisions of the bank and the execution of orders on the foreign market. The simplicity of this method results in difficulties in adequately assessing the effectiveness of the activities of bank divisions engaged in various active operations. Indeed, it is hardly possible to place a direct lending division and a division operating in the corporate bond market, where the basic market yield is significantly lower, in the same terms of payment for resources. Similar problems may arise in resource departments, one of which specializes in time deposits, while others specialize in settlement services for clients. Purchasing resources from these divisions at a single price may lead to a loss of interest in attracting more “expensive” time deposits. At the same time, leveling the imbalance in wages by establishing different bonus ratios for these departments cannot always ensure optimal management. Transfer pricing in this case may lose its purpose: risk management and adequate assessment of the activities of all divisions of the bank, namely, their profitability or payback.

The third option of transfer pricing assumes a difference in the transfer price when financing different types of assets at the expense of liabilities of different maturities. In other words, the transfer price when financing through demand liabilities will be different from the price of resources generated through time liabilities. This approach is based on the principle of dividing funds of funds, according to which, ideally, the “golden” rule of liquidity should be fulfilled, when demand liabilities are invested in highly liquid assets, and fixed-term assets are financed through fixed-term liabilities.

This method of separating sources of funds and establishing different levels of transfer prices depending on the type of source of resources seems much more attractive. In this case, the bank gets the opportunity to more flexibly manage its requirements and obligations, on the one hand, and more adequately assess the performance of its divisions, on the other hand. This method is more difficult to implement than the previous one, since it requires an increase in analytical work, but it allows you to more effectively manage market risks. The treasury in this case plays the role of an intermediary in resource management and ensures the smooth operation of the bank together with the risk management department or analytical service. One of the tasks of the treasury is to establish adequate costs for resources of varying urgency, which makes it possible to establish fair wages for various departments. Determining the directions for using raised funds is the task of the assets and liabilities management committee or the analytical department.

There are other transfer pricing options, which are a combination of the above cases. Each of the options considered has its own advantages and disadvantages. But whatever option the bank’s management chooses, it must take into account that differences in the above approaches to determining the transfer price lead to To significant differences in the assessment of the activities of bank divisions.

Lecture 8.

Strategic planning in commercial banks: concept, organization, methodology

Strategic planning as a necessary condition for the development of an organization

1.1. Strategic management. Strategic planning in the bank management system

Strategic management and strategic planning

Strategic management called management that relies on human potential as the basis of the organization, focuses the organization’s activities on customer needs, flexibly responds to timely changes in activities that meet the challenges of the macro environment and allows for competitive advantages, and carries out these changes, which together allows the organization to survive in long term and achieve your goals.
The objects of strategic management are both organizations, including credit institutions, and their individual functional areas.
Subject of strategic management are:
tasks related to the implementation of the organization’s strategic goals;
tasks and decisions related to any element of the organization, if this element is necessary to achieve goals, but is currently missing or insufficient;
tasks associated with external factors (macroenvironment) that are beyond the control of the organization.
Key differences operational management from strategic management are as follows. Firstly, the main goal (priorities) of the organization changes - from the production of goods and services in the short term to long-term successful development in the market. Secondly, the ways to achieve goals are adjusted. The organization focuses not only on the efficient use of resources, but also on finding new opportunities in competition, adapting and taking advantage of changes in the macro environment. Thirdly, the attitude towards the organization’s human capital is changing. An employee is associated not just with one of the types of resources of the organization - he becomes the source of its well-being. Fourthly, the criteria for the effectiveness of an organization's activities are measured not by indicators of profitability and rational use of production potential, but by flexibility and readiness for change.
Strategic management aims to solve three questions: where (in what position) is the organization now, where does it want to be in the future? nth amount of time and how to achieve the desired result. To solve the first question, an appropriate information platform is built, containing analytical assessments of past, present and future situations. The second question reflects such an important feature for strategic management as its orientation towards the future, and therefore requires a clear understanding of the owners of the organization of what to strive for and what goals to set. The third question is related to the implementation of the chosen strategy, during which the two previous questions may be adjusted. The most important components of this issue are the available or available resources, the management system, the organizational structure and the personnel who will implement the strategy.
Thus, essence of strategic management consists in the formation and implementation of an organization’s development strategy based on continuous monitoring and assessment of ongoing changes in its activities in order to maintain the ability to survive and operate effectively in an unstable external environment.
The “calling card” of strategic management is the development and adoption of specific strategic decisions for the development of the organization. Strategic decisions These are management decisions that are future-oriented and lay the basis for making operational decisions, are associated with significant uncertainty, since they take into account uncontrollable external factors, are associated with the involvement of significant resources and can have extremely serious, long-term consequences for the organization.
In relation to banks, strategic decisions include the reorganization of the management system, attracting capital investors, merger (acquisition) processes, modernization (towards increasing technology) of the bank’s product line, entering new banking markets, etc.
Strategic decisions have a number of distinctive features. Among them: innovative nature, focus on long-term goals and opportunities, complexity of formation given many strategic alternatives, subjectivity of assessment, irreversibility and high degree of risk.
TO principles of strategic management include the following.
Science combined with elements of art.
In addition to qualifications in the field of activity of the organization in which the decision is made, the manager must have knowledge in many sciences, be able to constantly improvise, look for individual approaches to the problem, be able to find a way out of the most difficult situation, focus on key weaknesses, and highlight the main advantages your organization and use them.
Focus.
Strategic analysis and strategy formation must be subject to the principle of purposefulness, i.e. be always focused on achieving the global goals of the organization. In contrast to free improvisation and intuition, strategic management is designed to ensure the conscious directional development of the organization and the focus of the management process on solving specific problems.
Flexibility.
This principle implies the possibility of making adjustments to previously made decisions or revising them at any time in accordance with changing circumstances. The implementation of this principle involves assessing the compliance of the current strategy with the requirements of the external environment and the capabilities of the organization, clarifying the adopted policies and plans in the event of unforeseen developments and increased competition.
Unity of strategic plans and programs.
To achieve success, strategic decisions of different levels of management and different areas of the organization's activities must be coordinated and closely linked with each other. The unity of strategic plans of organizations is achieved through consolidation and mutual coordination of strategies and operational plans of structural divisions.
Creating the necessary conditions for the implementation of strategic plans and programs.
Every strategic decision should be aimed at implementing the organization's development strategy. The process of strategic management involves the creation of organizational conditions for the implementation of strategic plans and programs - the formation of a strong organizational structure, the development of a motivation system, and the improvement of the management structure.
As noted above, basis of strategic management acts as a system of strategies consisting of interrelated specialized business and management strategies.
Strategy is a pre-planned reaction of an organization to changes in the external environment, the line of its behavior chosen to achieve the desired result. The strategy is drawn up in the form of a special document that formalizes the goals of the organization's activities for the long term, the means and methods for achieving them, the distribution of the organization's resources for the long term, taking into account possible changes in the external environment of activity and the priorities of the owners of the organization.
The process of developing, implementing, monitoring and controlling the implementation of a development strategy, as well as the process of keeping it up to date is called strategic planning.
Strategic planning is an integral part of strategic management, differing from it in the goals and scale of the tasks being solved. Strategic management involves making decisions based on strategically informed decisions on any issue of the organization's development, and strategic planning creates an information base for making such decisions.
The strategic planning process includes functions such as forecasting, strategy development, and business planning (budgeting). Forecasting precedes the development of strategic plans. It is based on an analysis of a wide range of internal and external factors (conditions) of the organization’s functioning, on the basis of which the possibility of development and risk assessment of the organization’s activities is determined. Forecasting traditionally uses three dimensions: time (strategic period of development), direction (future trends) and magnitude (materiality of change).
Taking into account the results of the analysis and forecasting, the organization's development strategy is formulated. Linking the strategic goals of the organization with the results of the activities of individual divisions is carried out through the development of the necessary program of action and drawing up a business plan (budget). Business planning (budgeting) includes the valuation of a strategy (development of tactical plans) and the allocation of resources in the interests of its implementation.
In order to organize the implementation of strategic and tactical plans, appropriate schedules are developed, a motivation system is introduced, a system of monitoring and control of their implementation is built, etc.
Organizing the implementation of strategic plans involves the formation of the future potential of the organization, coordination of the structure and management system with the chosen development strategy, and the creation of a corporate culture that supports the strategy.
The actions of managers in the formation and implementation of corporate strategy are coordinated by coordinating management decisions and consistent consolidation of the goals and specialized strategies of structural divisions in accordance with the corporate development strategy of the organization.
Motivation, as one of the functions of strategic management, is a system of incentives that encourages the achievement of set strategic goals. Monitoring and control involve continuous monitoring of the process of implementation of strategic plans. At the same time, threats are identified in advance, errors and deviations from the adopted strategies and programs of the organization are identified.

Strategic planning in commercial banks

Today, both scientists dealing with the problem of strategic planning and business practitioners directly involved in the management of an organization, using specific examples, have proven the necessity and benefit of a strategic management concept as the most successful in achieving goals and objectives and promoting the survival of an organization in a constantly changing macroenvironment.
It has been proven that organizations in which strategic planning has been introduced operate much more efficiently than organizations that carry out their activities on the basis of operational planning. This is evidenced by the performance indicators of such organizations and the fact that they have achieved their strategic goals.
Banks are no exception. A clear example of a credit organization that successfully uses strategic planning tools is Sberbank of Russia, which in a very limited period of time (two to three years) achieved strategic goals for modernization and technical re-equipment of banking customer services and turned from an inert, extremely conservative credit organization with an extremely low client attractiveness (non-price) to a bank with Western service standards, the highest level of technology and operational efficiency, setting the tone for the entire Russian banking community.
Strategic planning and, in particular, its main element - strategy - is a complex and potentially powerful tool with which a modern bank can withstand and even benefit from constantly changing operating conditions. At the same time, strategic planning as a management tool is not so easy to use; its implementation and use are sometimes expensive for the bank, and the result can only be understood after a certain time established by the strategy.
This circumstance partly explains the opposition on the part of bank managers and its employees to the introduction of strategic planning in the bank. One of the difficulties is related to the fact that in many banks the decision-making process is completely dependent on the management structure. The strategy introduces an element of rationalism that can destroy the type of relationship that has developed in the bank and undermine the policy of the board, which invariably strives for independence from shareholders. Accordingly, it seems natural to fight against the destruction of the existing relationships of the management structure and against the practice of taking responsibility for solving problems posed by the external environment.
Another, no less significant problem is that the introduction of strategic planning leads to a contradiction between previous activities that provide the bank with stable profits, and new ones, the benefits from which have yet to be received. As a rule, banks have neither the desire to think and act strategically nor the corresponding motivation.
However, the irony is that in order to develop, and even simply maintain the achieved positions, the bank needs strategic planning. The bank’s lack of a development strategy and an effective strategic planning system entails the emergence of a whole set of risks, including strategic risk, risk of loss of reputation, risk of lost profits, etc.
It is obvious that the bank suffers losses from unused opportunities (for example, opening sales points in large cities, using Internet technologies), which is due to the lack of formalized and transparent promising areas of the bank’s activities, an appropriate calculation of the necessary resources (financial, material and technical, human resources) ) and taking adequate organizational measures.
In addition, the bank faces a risk associated with the inability to implement the bank's plans to implement a holistic and continuous planning system. The absence of a planning system in a bank leads to a decrease in the efficiency of its activities, including taking into account business areas and business processes, demotivation of personnel to implement development tasks, lack of unity in approaches to process management, etc.
The formation of a centralized, transparent planning system is impossible without its key link - the development strategy and strategic financial plan, which is the basis for subsequent business planning and budgeting and the formation of a system of key performance indicators.
In the Russian banking community, long-term planning is often confused with strategic planning, while the main difference between the first and second types of planning is the interpretation of the future.
Long-range planning assumes that the future can be predicted by extrapolating historical growth trends. Bank management usually assumes that future performance results will certainly improve compared to the past, and, naturally, sets higher indicators. A typical result of this practice is the setting of optimistic goals that do not correspond to the actual results of the bank’s activities.
Strategic planning does not assume that the future must necessarily be better than the past, nor does it assume that the future can be studied by extrapolation. Therefore, as a first step, an analysis of the bank’s prospects is undertaken, the task of which is to clarify those trends, dangers, chances, as well as individual emergency situations that can change existing trends.
The second step is to analyze the position in the competition. Its task is to determine how much the bank's performance can be improved by improving the competitive strategy in the types of activities in which the bank is engaged. Typically, an analysis of competitive positions shows that some of them are more promising than others, and some are not promising at all. The third step involves comparing the bank's prospects in different activities, setting priorities and allocating resources among different activities to support future strategy.
In many cases, existing capabilities are unsustainable for the bank, either because the set of activities in which it is engaged is strategically vulnerable, or because there is a mismatch between long-term and short-term perspectives, or because the management of the bank claims to achieving growth rates that far exceed possible prospects.
In this regard, the next step is to analyze diversification paths. Its task is to assess the shortcomings of the current set of activities and identify new ones to which the bank should move.
By connecting the results expected from new activities with the line of current opportunities, the bank determines overall goals and objectives, the adequacy of which is determined by how large the goals the bank management sets for itself and how energetically it strives to achieve them, as well as by the extent to which these goals will be provided with strategic resources.
Next, the bank develops action programs, budgets and profit plans, developed for each of the bank's divisions, the implementation of which is then monitored.
To formulate plans, the bank must group tasks into short-term, designed for current implementation, and strategic, or long-term.
Current programs and budgets guide bank divisions in their daily work aimed at ensuring current activities, while strategic programs and budgets lay the foundations for the future development of the bank, which requires the construction of a special execution system based on project management.
When the idea of ​​strategic planning first arose, it was obvious that the ability to move into new activities depended on how well the bank would be able to function successfully in them. In this regard, one of the main rules for choosing a strategy was that new strategies, both in traditional industries and in new areas of business, must correspond to the accumulated potential of the bank. One of the first steps in developing the principles of strategic planning was an analysis of the bank's potential from the point of view of identifying its strengths and weaknesses.
However, it soon became clear that such a link to the accumulated potential of the bank limits the possibilities for strategic actions. Often, banks were unable to find a promising area of ​​this kind for themselves in which they could apply the accumulated experience. To build a truly successful strategy, banks should not be afraid to set themselves so-called breakthrough goals. At the same time, the main obstacle to their achievement may not even be the presence or absence of resources, but the resistance of internal bank management, which is based on five interrelated components:
1) qualifications and outlook of the bank’s leading managers;
2) social climate (culture of relations) within the bank;
3) management (power) structure;
4) working methods and organizational structure;
5) the ability of top and middle managers to conduct organizational work.
As experience has shown, in cases where planning is associated with the need for a fundamental change in the capabilities of the bank’s corporate management (for example, different qualifications of the board and heads of departments and offices are required, a different corporate culture and management structure), the implementation of the strategy encounters strong resistance within the bank. If strategy execution does not take steps to reduce, overcome, and manage this resistance, strategic planning risks being paralyzed.
Strategic planning is a process that affects all levels of bank management and lasts several months. This process is complex because it involves many external and internal factors, which are also constantly changing during planning. Surprises come from legislation, competitors, technological progress with its sudden breakthroughs, etc. To cope with such rapidly changing factors, strategy developers - this could be a specialized consulting company or a specialized bank service (strategic planning division), removed for objectivity beyond the existing management system - need to adopt the principle of timely decisions, or the so-called path management ranking of strategic objectives, which provides the following:
constant monitoring of all trends in the external environment of the bank’s activities: market, technical, general economic, social, political;
informing the bank's senior management about the results of the analysis of these trends;
dividing the bank’s tasks into categories: the most urgent and important tasks requiring immediate consideration; important tasks of medium urgency that can be solved within the next planning cycle; important but non-urgent tasks that require constant monitoring; unimportant tasks not worthy of further consideration (false alarm);
transfer of urgent tasks for study and decision-making either to existing divisions of the bank or, if necessary, to newly created specialized divisions;
establishing control over management decisions by senior management in terms of possible strategic and tactical consequences;
constant review and updating of the list of tasks and their priorities by the bank's senior management.
Strategic planning, based on an analysis of the external environment, contains an element of surprise.
Old strategies and plans are not replaced by new ones; information that needs to be mastered and studied flows in. The suddenness of changes in the macroenvironment and the likelihood of losses are so widely recognized by bank management that there is a threat of general panic. An initiative from below, which under normal conditions accelerates the adoption of countermeasures, in conditions of strategic surprise loses its effectiveness and may even turn out to be unsafe. Middle and lower management, finding themselves without instructions for action, begins to try to come up with something of their own and creates confusion.
In this regard, strategic planning provides for a system of emergency measures, including:
creation of a transparent information field that allows you to cross the boundaries of organizational units, filter information and quickly transmit it to all levels of the bank;
redistribution of senior management responsibilities, i.e. grouping efforts around the tasks of monitoring and maintaining a healthy moral climate in the bank, tuned to the implementation of the strategy; tasks of operational business management with a minimum level of disruptions; tasks of taking emergency measures;
testing the developed plans in individual areas of the bank’s activities.
It is clear that the process of developing a development strategy, as well as the process of establishing a strategic planning system in a bank, is multifaceted and quite complex. It requires material and intangible resources from the bank and requires readiness for change. However, all costs and changes are justified, since it is obvious that a strategy is necessary for both a small bank and a large one, because not only its position in the market, the operation of management systems, business processes, but also the very fact of the bank’s existence in the future depend on the bank’s strategy .

1.2. Stages of strategic planning

Strategic planning is a holistic and continuous process that includes three basic elements: developing a strategic plan (five to ten years), business planning (one to three years) and budgeting (one year) (Fig. 1.1). Each of the identified elements is accompanied by monitoring processes, accompanying key performance indicators and key indicators of goal achievement, management reporting and an analysis system.

The price of goods and services can be determined in various ways. One of these methods is transfer pricing (TP). Let's look at all its features.

What is transfer pricing?

Transfer pricing is the setting of value based on intercompany prices. They may differ from market ones. The main advantage of this method is the maximum reduction in company taxes. Its essence lies in the fact that there is a transfer of total profits in favor of firms located in countries with a minimum tax burden. Setting transfer prices has the following advantages:

• Distribution of spheres of influence between different branches of companies.
• Withdrawal of funds earned by subsidiaries from states with restrictions on the withdrawal of capital.
• Capturing a large part of the market by artificially reducing the cost of products.

Transfer pricing is relevant not only for large holdings, but also for representatives of small and medium-sized businesses. Reducing taxation and, as a result, increasing profits is achieved in completely legal ways. The final value is formed on the basis of the subjective properties of the object.

Regulation of transfer prices

The first laws relating to transfer pricing were adopted in the United States more than half a century ago. In the 90s, corresponding international standards appeared. In Russia, laws were adopted only in 2012. Transfer pricing is regulated by Chapter 6.1 of the Tax Code of the Russian Federation, as well as Articles 20 and 40 of the Tax Code of the Russian Federation. The regulations list situations in which tax authorities have the right to check the prices set by the company. Let's consider the goals of pricing regulation:

• Creating obstacles to artificially lower the profit received by the company.
• Elimination of barriers for companies that are bona fide taxpayers.

The laws of the Russian Federation are based on international experience. In particular, an important principle applies: comparing the prices set by interdependent firms with the prices that would be generated by independent companies.

In what case will transfer pricing be controlled?

Additional control is introduced regarding transactions with the following characteristics:

• Transactions between parties that depend on each other (including those involving a supporter).
• Transactions between Russian companies and representative offices of other countries.
• Transactions carried out on the foreign market with exchange-traded products (this includes, for example, metals). Additional verification is carried out only when the company’s annual revenue exceeds 60 million rubles.
• One of the counterparties is located in a zone with preferential taxation.
• For one of the counterparties the tax rate is 0%.
• The transaction is carried out with the participation of an entity that extracts natural resources and transfers funds to the mineral extraction tax treasury.
• Transactions between sister companies if their share of participation in the parent company is 25% or more.
• Transactions between the entity and its CEO.
• Transactions between enterprises in which the general director is the same person.

There may be other reasons for inspections. However, all of them must be confirmed by law. Control is carried out only when the transaction amount exceeds a certain level. As a rule, this is 60-100 million rubles.

In what cases will there be no control?

The list of transactions in respect of which additional control is not performed is determined by Article 104.4 of the Tax Code of the Russian Federation:

• Operations performed by representatives of the consolidated group that comply with the laws of the Russian Federation.
• Transactions carried out between persons with legal addresses within the same region.
• Transactions between enterprises that do not have separate divisions in other regions of the country or other states.
• Transactions between parties who pay tax to the budget of the same region.
• One of the parties does not have losses for the previous period, which reduce the tax burden.
• None of the participants switched to a special tax regime.

Regulations assume that the value of transactions between independent firms is a priori.

Who are the related parties within the framework of transfer pricing?

TP involves calculating costs based on prices established between interdependent parties. But what is meant by interdependent persons? These are companies that can influence each other's financial performance. Such firms are subject to special control by the tax authorities, since they have the ability to reduce the fiscal burden and remove profits from taxation.

Related persons can influence the following indicators of each other:

• Cost of transactions.
• Amounts of income and profit.
• Other economic parameters.

The interconnectedness of persons is determined according to the following principles:

• Direct or indirect participation of individuals or legal entities in the capital of the company, amounting to at least 25%.
• Family connection between FL.
• Availability of official subordination.

If there are other signs of interconnection, the tax authorities have the right to go to court and establish them. The characteristics can be recognized by companies on a voluntary basis.

Responsibilities of transfer pricing participants

Companies that create transfer prices have the following responsibilities:

• Annual submission to the Federal Tax Service on transactions subject to additional control. Notification must be sent by May 20 of the following period.
• At the request of the tax authorities, the company must provide all documents related to the transaction.

The company can be checked at any time for the objectivity of pricing.

Transfer pricing methods

Comparable market price method

The comparable market prices method is considered priority. That is, it can be used in all cases, excluding situations with legal restrictions. Its essence is to establish value based on prices for similar objects. This method is relevant only if there is information from open sources about prices for identical products. Let's consider situations in which the SRC method must be used:

• A transaction with a counterparty, the terms of which are identical to the terms of internal transactions carried out by the entity.
• Issuing a loan.
• Trademark development.
• Transactions with products for which there are stock quotes or other statistical data.

In all these cases, you can find information about the prices of objects that are comparable to the object being sold.

Resale price method and cost method

The principle of applying the subsequent sale price method and the cost method lies in the fact that in this case the market range of profitability of independent persons is compared with the gross profitability acquired as a result of a transaction with a person who is dependent on the company.

For example, a company purchases products from a related party and then sells them to an independent party. In this situation, the subsequent sales price method is relevant. Within its framework, the distributor’s receipt of gross profitability (GR) and the objectivity of purchase prices are checked. The resulting value must be compared with the BP of independent distributors. If the BP within the transaction is within the market interval, the purchase price is recognized as market value.

The cost method involves analyzing not purchase prices, but selling prices. It is necessary to compare the BP of spending with the market interval of independent persons.

The listed methods are used quite rarely. This is due to the fact that it is quite difficult for the company to find data on the BP of independent persons. In addition, the transactions being compared must be comparable.

Comparable profitability method

The comparable profitability method is quite popular. Within its framework, the parameters of operating profitability are taken into account. Let's consider the stages of applying the method:

1. Conducting functional analysis.
2. Selecting the participant to be tested.
3. Selection of financial indicator.
4. Finding the source of data.
5. Search for companies whose performance is comparable.
6. Determination of the market profitability interval.
7. Comparing the profitability of the tested participant with the market interval.

Let's look at an example. The company is engaged in wholesale purchases. That is, you need to find organizations that also specialize in wholesale purchasing. Then, companies whose information is not publicly available are excluded from the resulting list. After this, the market interval is determined. After this, the profitability of the entity is compared with the profitability of comparable organizations.

IMPORTANT! The method will be relevant if there is no completeness of data to apply the above methods.

Profit distribution method

This method is used extremely rarely. This is due to the fact that it is very complex. Its essence lies in the redistribution of profits of all participants in the operation in proportion to the functions they performed. When making distributions, you can focus on the features of distribution between independent participants within a comparable transaction.

Sources of information

TC involves the use of a certain list of data. The necessary information can be taken from sources such as:

• Data on prices of stock and commodity exchanges.
• Customs statistics.
• Information posted on government resources.
• Information received by information and pricing organizations.
• Data on comparable transactions already carried out by entities.
• Financial and statistical reporting.
• Conclusion received from independent appraisers.

The company also has the right to use other information that is needed for adequate pricing.

ATTENTION! The sources used must be verifiable. This is required to ensure the possibility of checking the adequacy of the shopping center.

Main tasks of transfer pricing management

The tax service is responsible for managing the shopping center. Management is necessary to solve the following tasks:

• Ensuring work to verify established prices by local tax authorities.
• Analysis and assessment of processes occurring in the market.
• Control over compliance with the law of the country.
• Review of applications regarding pricing agreements.
• Formation of proposals to improve legislation in the area under consideration.
• Informing enterprises about innovations.
• Ensuring the stable operation of regulatory authorities.

Tax authorities have the right to inspect companies and request the necessary documents. Based on the completed inspection, fines are issued.

Required documents

An enterprise must maintain documentation on a shopping center when the amount of its income from transactions with the same participant is more than 100 million rubles. The form of documents is not established by law, but the papers must contain the following information:

• Activities of participants in controlled transactions.
• List of participants in operations.
• Information about the transaction: conditions, selected pricing method, payment receipt deadlines.
• Information about the parties to the transaction: their functions, existing risks.
• Explanation of the choice of price formation method.
• Links to data sources used in pricing.
• Data on income and expenses for the operation.
• Data on adjustments made to the tax amount.

The documents must contain information that could affect the pricing of the transaction.

ATTENTION! The tax service has the right to request transfer pricing documentation from the company. Documents must be submitted to the service within a month from the date of the request.

Reporting

The new rules oblige the company to submit reports on transactions performed to the tax service only if the income from the transaction amounted to more than 100 million rubles. Documentation must be submitted no later than May 20 of the following year. The document must include the following information:

• Subject of the operation.
• Information about the participants in the transaction.
• Data on income arising from the transaction.

Tax authorities have the right to check the accuracy of the trading price. This is necessary to control the payment of taxes in full.

ATTENTION! The burden of proof of the adequacy of transfer prices lies with the tax authorities, not the company. That is, the tax service cannot oblige the enterprise to prove the validity of the trading price.

Legal liability of the company

If the audit reveals a discrepancy between the established prices and the market prices, the tax authorities may oblige the company to pay additional tax taking into account the completed transaction. The company may also be subject to a certain fine. If a discrepancy is detected for the years 2014-2016, the fine will be 20% of the amount of unpaid tax, for 2017 - up to 40%. To establish a fine, the enterprise's violation must be proven. For this purpose, organization documents and other sources can be used.

Since 2016, control over transfer pricing—transactions in which prices are set below or above market prices—has been tightened. What businesses need to know about working in the new conditions, says Elena Zhuger, director and founder of BelAuditAlliance.

There are different schemes for building a business in Belarus. It has become standard to build a network of subsidiaries with the same type of activity, but with preferential conditions - for example, using the simplified tax system in small towns, creating FEZ and HTP resident companies, using such a form as individual entrepreneurs.

The founders and managers of such businesses are wives, children, brothers and sisters, other relatives and other controlled persons. In such cases, companies sell each other a product or service at a better price or at a price different from the market price. This allows you to redistribute your overall profits and pay taxes on them at lower rates or not at all.

The newly introduced rules of the Tax Code in the field of transfer pricing, with a healthy desire to pay less taxes, oblige taxpayers to act within the established rules. The desire to “go around” or not to comply with the rules (perhaps they won’t be found) can be fraught with serious financial losses for the business.

I will give examples.

Example 1. There are 2 companies

• Company A applies a general taxation system
• Company B applies a simplified taxation system

The founders of company A are two men. The founders of company B are their wives. Company A imports goods and sells them with a minimum markup below the market price (deviation from the market price more than 20%) to company B. For this, company A receives minimal revenue. At the end of the reporting period, it may have losses. In this case, no income tax will be paid.

Company B sells goods at market prices and pays 5% on turnover.

Thus, company A pays minimal value added and profit taxes (sometimes does not pay at all). Company B, using a simplified taxation system, pays minimal tax on revenue. In light of the new approach to transfer pricing, at the time of tax calculations, Company A's profit should be increased by the amount of revenue as if the goods were sold at market prices. Accordingly, income tax will be increased.

Example 2. Citizen A is the founder of CJSC T with a 45% share and a member of the supervisory board of this company.

At the same time, he is the founder and director of P LLC. CJSC "T" purchases materials from LLC "P" for the manufacture of products at prices different from the market value + 20%, that is, more expensive. OJSC “T” minimizes profit tax due to inflated costs for materials.

In 2016, such expenses, in the event of a tax audit, may be excluded from expenses, and additional income tax will be charged.

An elementary attempt to save money leads to significant losses and problems. As you understand, there can be many such situations. All of them are examples of transfer pricing (general part of the Tax Code, Article 20).

In simple words - what is transfer pricing?

Transfer pricing is the sale of various services or goods by interdependent persons, which is carried out at prices different from market prices.

Using transfer pricing, organizations minimize taxes. This must be done in such a way as not to violate legal requirements and not entail additional financial losses and penalties from the tax inspectorate. Transfer pricing came to us in 2012.

In the period from 2012 to 2014, only transactions for the sale of real estate and the sale of goods to foreign companies/individuals as part of foreign trade activities were under control. Since 2015, the list of controlled transactions has been expanded - control has been added for work performed and services provided within the framework of foreign economic activity.

Since 2016, transfer pricing has covered almost all areas of activity - both foreign economic and domestic markets. Tax authorities will pay attention not only to the sale of goods, works, services, but also to transactions related to the sale of property and property rights.

Transactions with interdependent persons also come under control.

Interdependent persons - who are they?

This concept is an innovation for the Tax Code in 2016. Related entities are companies or individuals, the relationship between which has a direct impact on the conditions or economic results of their work/the activities of the persons they represent.

To put it simply, these are relationships:

1. Between persons who are founders (participants) of one organization.

2. When one person acts as a founder (participant) of another organization, if the share of his direct/indirect participation is at least 20%.

3. When one person is subordinate to another by position or one person is (directly or indirectly) under the control of another person.

4. Between organizations, if one person directly and (or) indirectly participates in these organizations, and the share of such participation in each of these organizations is at least 20 percent.

5. When individuals are married, closely related, are adoptive parents or adopted children, and other similar cases.

6. Between the grantor, the trustee and the beneficiary. Also - between the trustee and the organizations he manages.

7. Between organizations whose board of directors (supervisory board, etc.) consists of more than 50% of the same individuals. Moreover, their share of participation in organizations is at least 20%.

The concept of “related parties” is present only in tax legislation and only for tax legal relations.

Typical situations in which transfer pricing arises:

If you are not the founder of the company, but give instructions to the director about transactions.

If you sell your property to a leasing company and then rent it at a price different from the market price +/- 20%.

If you are an importer and your supplier supplies you with goods at prices different from market prices.

If one holding company supplies another holding company with raw materials at prices below market prices.

Who will the auditors come to first?

Since 2016, all companies and entrepreneurs, without exception, must:

1. Provide information about related parties and transactions with them.

2. Provide information about major transactions to the Ministry of Taxation and provide data on them justifying the transaction price.

3. Prepare a package of documents on the economic justification of prices for transactions with related parties.

First of all, the check will come:

1. To enterprises that have been unprofitable for several years (two or more years) in a row.

2. Part of international companies (i.e. having interdependent organizations abroad).

3. Companies reflecting an insignificant amount of profit - with significant volumes of goods sold for two or more years in a row (if this ratio is not determined by the industry characteristics of the payer’s activities).

4. To organizations whose profitability level is below the industry average. The level of profitability is determined from Belstat information by type of activity for the corresponding tax period.

5. To interdependent persons who sell real estate.

6. For companies carrying out foreign trade activities with a foreign counterparty - if there are signs of interdependence with it, and also if such counterparty is permanently located in a country (territory) with a level of profit taxation lower than in Belarus, is a resident of free (special) economic zones with preferential tax regime, etc.

3 types of transactions that are subject to control

Real estate transactions(sale or purchase), including through housing bonds, shared construction.

Foreign trade transactions- if the sum of purchase or sale prices of products (services) for one tax period with one person exceeds 1 billion Belarusian rubles. Indirect taxes are not taken into account.

Taking into account these conditions, the following come under control:

1. Transactions with related parties

2. Transactions with a person located in an offshore zone

3. Transactions with a related party or a resident of an offshore zone, which is carried out through a set of other transactions with the participation of an intermediary. Moreover, such an intermediary (third party) is not interdependent, does not perform any additional functions in the transaction, and does not participate in it with assets.

4. Transactions, the sum of prices for one tax period exceeds 10 billion Belarusian rubles, and they relate to:

• Purchases/sales of products from the list of strategic goods determined by the government (this list has not yet been developed).
• Purchases/sales of goods (works, services) by organizations included in the list of large payers.

3. Transactions made in our country, if their amount for one tax period with one person exceeds 1 billion. In this case, the person:

• Interdependent, is a tax resident of Belarus and uses special tax regimes
• Or registered in the HTP or SEZ

Or does not calculate and pay tax (exempt from tax) on profit in the period when the transaction was made

Who is responsible for transfer pricing?

There is a stereotype that in an organization the chief accountant is responsible for everything related to pricing and tax calculation. In fact, the director is responsible for organizing transfer pricing work.

Performers are specialists who directly carry out the purchase and sale of goods, works, and services. The chief accountant only collects information, submits reports on it, and takes it into account when calculating income tax. Information on transfer pricing will be provided to the tax authorities through marks in electronic invoices, which will come into effect from July 1, 2016.

If the tax authorities “like” your transaction, they have the right to request all documentation confirming the economic justification of the price applied by the payer.

The procedure for monitoring transfer pricing by tax authorities is not yet clear; the practice will be developed.

In order to avoid becoming “objects for training”, we recommend starting work now on organizing documentary support for the transactions being made. The first thing to do is make a list of interdependent persons.

Director and founder of the company "BelAuditAlliance".

Certified auditor. Chairman of the Committee on Methodology and Audit of the Association of Auditing Organizations.

• Kozhin Vladimir Alexandrovich, Doctor of Sciences, Professor, Professor
• Nizhny Novgorod State University of Architecture and Civil Engineering
• Kurzina Elena Vladimirovna, master
• Nizhny Novgorod Institute of Management and Business
• Shagalova Tatyana Vladimirovna, Candidate of Sciences, Associate Professor
• NOU VPO Nizhny Novgorod Institute of Management and Business

• BUDGETING
• TRANSFER PRICING
• PRICE POLICY
• COMMERCIAL BANKS
• LIQUIDITY

The decisive place in the banking marketing system is occupied by pricing policy, the main content of which is establishing the required price level for banking products of various kinds and changing them according to the specific market situation.

• The banking sector of the Russian Federation and prospects for its development in modern conditions
• Goals, objectives, functions of management in the financial and credit sector
• Organization of staff motivation in budgeting conditions

The relevance of the study of pricing policy is determined by the fact that in the context of tightening liquidity requirements for banks, expected in connection with the implementation of Basel III provisions, banks strive to optimize the liquidity management process, making maximum use of the tools available for this. One of these tools is pricing.

The pricing policy of an enterprise is the establishment (determination) of prices that ensure the survival of the enterprise in market conditions. It includes choosing a pricing method, developing an enterprise pricing system, determining market pricing strategies and other aspects.

To justify the price level, each enterprise chooses its pricing policy based on the prevailing circumstances determined by the actions of external and internal factors. Since these factors are constantly changing, different pricing policies are used in practice. The most common of them are.

• incentive;
• based on division of markets;
• competition oriented;
• premium, as well as a policy of penetrating and declining prices.

Let's consider the pricing process in Banks.

The efficiency of the Bank's activities depends on various factors: asset and liability management; risk management systems; the chosen development strategy of the bank, reflecting the development of the economy, both at the national and global levels; efficient use of financial resources. These tasks are solved by the Bank's management. One of the most important participants in the Bank's management is the treasury.

Currently, one of the main tasks of the Bank's top management is the development and implementation of business development projects. Trying to attract as many resources as possible to carry out its activities within the framework of such projects, the Bank is trying to occupy a large market share by promoting its banking products and programs in the regions. Such territorial expansion consists of creating regional bank branches.

Of course, the influx of additional funds from attracting new clients is a positive result of business development and gives a new impetus towards increasing profitability in general. However, the total volume of operations performed also increases, and with it the load on the Bank’s management system and, in particular, on its basis – the budgeting system – increases.

The resources attracted by the Bank continue to move, being redistributed between the bank's divisions. Thus, the cost of attracted and redistributed resources for the Bank is not the same. Taking into account this provision, the key to effective management of the Bank is the optimal distribution of all received resources between them. The instrument for such distribution is the mechanism of internal transfer pricing, which allows you to determine the real prices at which divisions receive financial resources, which is certainly important in the budgeting process both at the stage of budget formation and at the stage of monitoring and analyzing their execution and determining the effectiveness of each divisions. In addition, the transfer pricing mechanism allows you to distribute risks between departments (credit risk - to the department involved in the allocation of resources, interest rate risk and liquidity risk - to liquidity management).

As noted by M.Yu. Kulaev, “the advantage of the budgeting model with transfer pricing is its high accuracy in assessing financial results, which stimulates all departments to increase profitability and develop a business area, relative simplicity and practical testing.”

The Treasury of Banks performs the most important function - the distribution of internal liquidity. The internal budgeting system is designed to ensure control over the distribution of liquidity, as well as to assess the efficiency of the activities of business units included in the Bank's structure. In the course of their activities, the Bank's structural divisions sell their net liabilities and buy net assets from the Treasury to fund active transactions at transfer prices. The Treasury regulates financial flows within the Bank and determines transfer prices, implementing the function of centralized management of the Bank's resources.

As noted by A.S. Namestnikov, “the redistribution of financial resources within the bank using transfer prices is a management reporting tool and does not lead to the real movement of funds. The corresponding financial results of independent divisions are calculated by the bank’s analytical divisions in the process of generating management reporting.”

The main tasks that the use of transfer pricing in a commercial bank is aimed at can be divided into four groups:

1. centralized risk management. The use of transfer pricing allows you to free business units from the following risks by transferring them to the Treasury: liquidity risk, interest rate and currency risks;
2. assessment of the performance of individual business divisions of the bank. This assessment allows you to analyze the effectiveness of departments, formulate a system of employee motivation, and also helps management make strategic decisions on the direction of development of the credit organization;
3. pricing of client products. Transfer prices are a guideline for pricing interest-bearing client products (for example, loans and deposits);
4. budget planning process. Planning interest income and expenses by business area, as well as ensuring control over the use of resources and financial discipline, profitability and self-sufficiency of the bank's structural divisions.

The transfer pricing mechanism begins to work at the stage of determining prices in the process of forming the budget of income and expenses. This, in particular, characterizes the importance of this tool in management. The accuracy and correctness of setting transfer prices is the basis for fulfilling the general performance standards developed by the bank, such as current liquidity, profitability of individual assets, capital adequacy, etc., which are one of the main pricing criteria. Transfer prices must be determined in advance, since profit centers will plan the volume of active and passive transactions based on their level.

The essence of the transfer price lies in the specifics of banking activities, namely the presence of an attracting and placing division. Management accounting specialists call such units financial responsibility centers. The term “responsibility center” refers to a structural unit whose managers make most of the management decisions regarding financial activities locally and which is accountable to a higher management body for the results of its activities. This is a form of organizing management control in decentralized companies.

V.Yu. Selezneva emphasizes that “if any center of financial responsibility works only to attract (allocate) resources and does not carry out active (passive) operations, then it initially cannot have a profit, and its budget of income and expenses consists only of expenditure (revenue) parts."

It is not possible to assess the effectiveness of such a financial responsibility center. But one of the tasks of budgeting as a management tool is precisely to analyze and determine the effectiveness of the activities of all departments. The introduction of transfer prices is intended to solve this problem. The transfer price is the price of financial resources redistributed between centers of financial responsibility. It is the introduction of such pricing that makes it possible to show their transfer income or expenses, i.e., internal income (expenses) of the Bank’s financial responsibility center from the sale (purchase) of resources on the intrabank market. According to M.V. Panova, the calculation of the transfer price should take into account the following:.

1. The marginal costs of the parent Bank for attracting its own liabilities are calculated:

PZgb=(PPZ+POZ)/(1-Nro), (1)

Where PPZ – maximum interest costs of the parent bank for attracting its own liabilities;

POS– marginal operating costs for servicing liabilities,

Nro– standard for contributions to mandatory reserve funds.

This calculation is made because marginal costs are based on market interest rates and reserve requirements, making them reasonable.

2. The transfer price of the Central Bank for attracting resources by the Treasury from those Central Federal Districts that are engaged in raising funds in the branch network is calculated as alternative costs for attracting similar resources from the parent bank:

Tspr=PZgb (2)

Based on the calculated marginal costs of the Bank, branches receive a kind of beacon - how much money needs to be raised from passive activities, and the parent Bank itself receives a beacon - how much money needs to be raised from active activities.

Bank branches (where the main credit resources are attracted) make a profit Pfil, if their marginal costs are less than the marginal costs of the parent Bank (i.e. if the transfer price for deposits attracted from branches will be higher than the interest costs on attraction and the actual costs of the branch):

PZgb>PZfil, or Pfil=Tspr – PZfil. (3)

The Parent Bank makes a profit if its income (as the center performing the largest volume of active operations) exceeds the calculated marginal costs of attracting liabilities (i.e., the transfer price for financing loans and the actual expenses of the center are lower than the income from the active operations of the center). The level of transfer prices in the Bank is reviewed monthly.

This pricing mechanism contributes to more efficient management - this simplifies the analysis of the performance of financial responsibility centers. This pricing method allows for optimal distribution of resources between the Bank’s divisions and also serves as an external pricing tool. In addition, this pricing mechanism is aimed at reducing the costs of branches and the parent Bank. Which in turn makes it possible to reduce interest rates on lending and increase the competitiveness of the Bank.

In addition to everything said above, in terms of pricing for bank interest and Bank services, pricing formulas can be presented in the following form:

BP = Ptsb + Ib*Kr*Knds + NS, (4)

Where BP- bank interest;

Ptsb- key rate of the Central Bank, in%;

Ib- bank costs, in%;

Kr- profitability coefficient,

Knds- VAT coefficient,

NS- markup, discount, in %.

For Bank services, the price per unit of service can be calculated according to:

Ub = S*Kr*Knds+NS, (5)

Where Ub- bank services, in rubles.

WITH- cost of the service, in rubles

Kr- profitability ratio,

Knds- VAT coefficient,

NS- markup, discount in rubles.

Summary. Correct pricing is one of the key components of organizing budgeting in a bank and its branches, the basis of their efficiency and stability in market conditions.

Bibliography

1. Federal Law of December 2, 1990 No. 395-1 (as amended on December 1, 2014) “On Banks and Banking Activities” // Rossiyskaya Gazeta. – 1996. – February 10.
2. Kozhin V.A., Ivanova O.S., Shagalova T.V., Improving modern methods of express diagnostics and analytical budgeting capabilities for enterprises in the conditions of the financial and economic crisis. // Audit and financial analysis. – 2010. - No. 1.
3. Kulaev M.Yu. Management of assets and liabilities of a credit institution, interest rate risk and liquidity risk based on transfer rates. // Audit and financial analysis. – 2008. - No. 1.
4. Namestnikov A.S. Advantages of using transfer pricing in a commercial bank. // Humanities and social sciences. – 2013. - No. 5.
5. Panov M.V. Transfer pricing in the process of budgeting the activities of a commercial bank. // Financial management. – 2007. - No. 3.
6. Selezneva V.Yu. Transfer pricing mechanism in a multi-branch commercial bank. // HSE Economic Journal. - 2002. - No. 1.
7. Sklyarenko V.K., Kozhin V.A., Pozdnyakov V.Ya. Economics of organizations. – N. Novgorod: NIMB. 2006.
8. Financial and credit encyclopedic dictionary // Ed. A.G. Gryaznova. - M.: Finance and Statistics, 2004.
9. Shalyapin A.P. Methods for statistical assessment of the efficiency of bank business units within the framework of the transfer pricing concept. // Economic Sciences. – 2013. - No. 6.