International Transfer Pricing and Intellectual Property: The PrimeCo Case

This case introduces students to issues related to international transfer pricing for intellectual property. PrimeCo is a manufacturer of cellular telephone (cell phone) components. The firm has invested extensively in research and development activities. As a result, it has received many patents for innovative cell phone parts. PrimeCo recently established a subsidiary (SubCo) to manufacture its products for the Asia‐Pacific region. The establishment of SubCo raises many difficult questions. Specifically, students are asked to address issues related to modes of entry into foreign markets, methods of transfer pricing in royalty arrangements, tax laws underlying transfer pricing, and ethical aspects of applying transfer prices.