transferpricing.us

Cost Plus Method

Price a maker's goods the way an independent maker would: its cost of production plus a fair gross markup. Then learn why a gross markup and a net markup are never the same number.

7 minutes, five short steps

  1. Guess
  2. Play
  3. Explain
  4. Check
  5. Try it

First, a bet

A maker produces parts and sells them to a related company in its group. Under the Cost plus methodA method that adds an arm's length gross markup to the supplier's cost of goods. It is common for manufacturers and service providers.Open in the Glossary, you start from the maker's costs and add a markup that independent makers earn.

The cost plus method adds a markup to which costs?

Build the price

A US maker of valve parts produces an order for its related distributor abroad. It also sells the same kind of part to an unrelated customer. Set its cost of production, choose where the markup comes from, and watch the price build up line by line.

Price to the related distributor$4.80mcost $4.00mgross profit $0.80m$0m$2m$4m$6m$8m

The maker's costs

The gross markup

Gross markup from
Cost accounting
  1. Cost of productionmaterials, factory labor and factory overhead$4.00m
  2. Cost base$4.00m
  3. Arm's length gross markupthe same maker's sale to an unrelated customer: $0.4m gross profit on $2.0m of cost20.0%
  4. Gross profit$4.00m x 20.0%$0.80m
  5. Arm's length price$4.00m x 1.200$4.80m

Cost, plus a gross markup

The formula is short: price = cost of production x (1 + gross markup). The Gross markupGross profit divided by the cost of the goods or services sold. It is the measure the cost plus method compares. Unlike a net markup, it is measured before operating expenses.Open in the Glossary is gross profit divided by cost of goods sold, taken from comparable sales between independent parties. Under US rules it is ordinarily used for goods that a company makes or assembles and sells to related parties.

The best data is an Internal comparableA comparable deal between one of the related companies and an unrelated party, such as the same seller selling the same goods to an outsider. Its facts are easy to check, so it is often, but not always, the most reliable comparable.Open in the Glossary: the same maker selling similar goods to an outside customer. Same factory, same books, so the costs line up. Next best are independent makers doing similar work. The products can differ more than under a price comparison (Comparable uncontrolled price (CUP)A method that compares the related-party price with the price charged in a comparable deal between unrelated parties. It is the most direct method when good comparables exist.Open in the Glossary), but the functions, risks and contract terms must be close, or you adjust for the differences.

The weak spot is accounting. One company books supervision, warehousing or quality checks in cost of goods sold, another books them as operating expenses. The gross markup changes with it. So you put the same costs on the same lines before you compare, as the calculator did with the factory supervision. For services, the US has a twin: the cost of services plus method. It adds a gross services markup to the costs of the service, and it is used most when the company sells the same service to outsiders.

Gross is not net

Now the Mexico Contract manufacturerA company that makes goods for another group company, to that company's orders and specifications, often using its technology. It bears little risk and earns a routine return, usually a markup on its costs.Open in the Glossary from the running story. The US Entrepreneur pays it cost plus 8%. Its numbers here are simple ones made up for this example, separate from the Price Dial's. That 8% is a net markup: operating profit over total costs, including its own operating expenses. It is the Net cost plusOperating profit divided by total costs (cost of sales plus operating expenses). It is the usual profit level indicator for routine manufacturers and service providers.Open in the Glossary tested under the Comparable profits method (CPM)A US method that tests a company's operating profit against the operating profit of comparable companies, using a profit level indicator such as operating margin (Treas. Reg. § 1.482-5). It is close to the OECD's TNMM.Open in the Glossary, not the cost plus method. Same company, same year, two very different numbers:

gross profit $0.80m/ $4.60m = 17.4% grosscost of goods sold $4.60mtotal costs $5.00moperating profit $0.40m/ $5.00m = 8.0% net
The Mexico maker's year in this example: $5.4m of sales to the US Entrepreneur.

A gross markup has to pay for the company's operating expenses and still leave a profit. A net markup is what is left after them. Never test one against the other.

Source: Treas. Reg. § 1.482-3(d), the cost plus method; § 1.482-9(e), the cost of services plus method; § 1.482-5(b), the CPM and its profit level indicators

Check yourself

Three quick questions. Each answer explains itself, right or wrong.

Question 1 of 3A maker's cost of producing an order is $3.0m. Comparable makers earn a 15% gross markup on the same kind of costs. What is the arm's length price under the cost plus method?
Question 2 of 3The comparable makers count factory supervision inside cost of goods sold. Your maker books the same costs as operating expenses, below gross profit. What should you do before you use their gross markup?
Question 3 of 3The Mexico contract manufacturer earns cost plus 8% on its total costs. An independent maker reports a 17% gross markup. Is the Mexico maker underpaid?

0 of 3 answered.

Try it for real