Aerial view of Leman lake -  Geneva city in Switzerland

Navigating the complexities of transfer pricing in commodity trading


M&A trends, AI integration and decarbonization are redefining transfer pricing for commodity traders.


In brief

  • M&A trends in oil and gas are driving the need to align transfer pricing with new operational structures.
  • Industry consolidation and vertical integration are some of the challenges demanding sophisticated models for commodity traders’  transfer pricing.
  • These developments coincide with global minimum taxation – and can be an opportunity for commodity traders.

In the intricate world of commodity trading, transfer pricing stands as a critical component, shaping the financial landscape and influencing strategic decision-making. This article delves into the nuances, specifically in light of mergers and acquisitions. We examine challenges and opportunities, offering insights into the evolving models that govern the arm's length principle amidst a rapidly transforming global market.

M&A surge

Commodities, specifically within the oil and gas industry, are currently navigating a dynamic environment where mergers and acquisitions (M&As) are on the rise, despite broader economic headwinds. This trend reflects a strategic pursuit of growth and efficiency, with companies keenly aware of the enduring importance of oil and gas in the global energy landscape. As a result, there is a concerted effort to align acquisitions with long-term strategic objectives, ensuring that each asset is managed by the most suitable operator to optimize performance and financial returns.

Decarbonization agenda

Amid this wave of consolidation, the commodities industry is also addressing the pressing issue of decarbonization. Companies are not only focusing on traditional oil and gas operations but are also expanding into low-carbon businesses. This dual focus requires a careful balance between maintaining profitability in core areas and investing in sustainable energy solutions. The transition to a low-carbon economy is prompting oil and gas firms to reevaluate their operations and explore different business models that can accommodate the unique demands of these emerging sectors.

Artificial intelligence (AI) in the oil and gas industry

Technology, particularly AI, is playing a pivotal role in transforming the industry. The adoption of AI and related technologies is enabling companies to make more informed and strategic decisions across all facets of their operations. By integrating AI into their workflows, oil and gas companies are positioning themselves for greatly enhanced operational efficiency and innovation. The strategic use of technology is not just about enhancing current processes but also about driving a fundamental shift in how the industry operates, with a strong emphasis on data-driven decision-making and risk management. Companies that are quick to embrace these technological advancements are expected to gain a significant competitive edge in the coming years.

Arm’s length principle and the comparability challenge

The arm's length principle is about setting fair transaction prices between related entities to ensure they are comparable to prices between independent entities. This prevents tax avoidance by ensuring related parties transact as if they were strangers. However, in the oil and gas industry there are not many “strangers” for two primary reasons. Firstly, the industry is experiencing significant consolidation due to heightened M&A, as discussed above. Secondly, there is a notable trend of vertical integration, with commodity traders venturing beyond their traditional midstream roles to upstream activities such as oil exploration and drilling. They are also acquiring downstream assets like refineries and retail gas stations. This expansion across the supply chain reflects a strategic move by commodity traders to control more aspects of the production and distribution process, thereby reducing reliance on external parties and enhancing their market position.

For these reasons, the industry presents a challenge in identifying comparable data from independent enterprises to infer a reasonable estimate of an arm's length outcome. Under these specific circumstances, transfer pricing becomes more of an art where judgement must be exercised. However, transfer pricing policies will typically be based on two-sided methodologies that rely on complex and sophisticated financial models, resembling more of an exact science than an art form. Transactional one-sided methods (e.g., comparable uncontrolled price (CUP)) are seldom applied – despite the ready availability of publicly quoted prices – due to the lack of comparability resulting from the high degree of vertical integration.

Shared features of the financial industry and commodity trading

There are key common factors between the financial and the commodity trading industries and, in fact, many traders have a background in investment banking. For instance, complex financial instruments such as futures, options and swaps are employed for hedging or speculative purposes. Players in both industries operate with a high degree of leverage, amplifying potential profits as well as risk. The risk management techniques employed in both industries are very sophisticated too, including value at risk (VaR) and stress testing to manage the unique risks associated with market volatility and commodity price fluctuations. In addition, there is high correlation between financial and commodities markets that have a direct impact on performance and both industries are highly sensitive to macroeconomic factors such as interest rates, inflation and currency exchange rates.

Spotlight on transfer pricing (TP)

The similarities observed between these two capital-intensive industries are also present in their TP policies. For instance, the use of capital by the parties undertaking the relevant risk-bearing functions represents a key source of economic benefit. For that reason, capital is generally employed, depending on the facts and circumstances, as a profit level indicator to test against comparable uncontrolled data, when available, or as profit split factor when it captures the relative contribution of the parties to the global (residual) trading or investment profits. Specifically, global trading desks of financial or physical assets at financing institutions and commodity traders respectively jointly undertake the key profit generating functions with a degree of integration such that TP policies are based on two-sided methodologies (e.g., profit split method).

With regard to commodity traders specifically, there are other factors besides capital that contribute significantly to global trading income, including strategic assets and infrastructure. Depending on the interplay of capital and assets, a TP policy might state that both act as cumulative splitting factors. There might be instances where capital might be factored in to determine a minimum return while the assets would ascertain the relative contribution to the residual global trading income. 

Operating models in light of the M&A surge

When a commodity trader grows through M&A, it is important to reevaluate the transfer pricing models to align with the new post-acquisition operational structure. The extent to which the TP model needs to change depends on the nature of the assets acquired and how closely the new entity will be integrated into the existing operations. For example, acquiring a stake in a company that strengthens the trader's role in the supply chain will likely require a reassessment of the factors that drive the current TP model (i.e., key value drivers of trading profit generation).

 

Similarly, if a trader acquires a company to establish a presence in a new geographical market, and the new company is expected to operate independently as a regional hub, the existing group TP model may not need significant changes. In such cases, the traditional centralized TP approach, which assumes an integrated operation sharing global profits, may not be suitable. Instead, transactions between the new entity and the rest of the group will likely be of supportive nature and a routine return will be in line with the arm's length principle.

 

Challenges and opportunities of GloBE Model Rules

The BEPS project has brought challenges and opportunities for commodity traders. The main challenge has been the alignment of TP outcomes with value creation, specifically the high scrutiny of contractual and actual allocation of risks, the financial capacity to bear risks as well as the exercise of control over risks (i.e., people functions). Since risks and capital follow functions, the people functions are considered to be executed wherever the traders are based, the key risks borne and the capital employed. A pragmatic way for tax authorities to identify where all this happens, i.e., the location, is by verifying the remuneration of employees assumed to carry out the people functions. Typically, high compensation with a variable component linked to the company’s profitability is an indicator used to confirm the actual location of the people functions and thus the allocation of profits. When there is a discrepancy between the location of capital and people functions, the risk-adjusted return attributed to capital might be adjusted downward to not more than a risk-free return.

 

The burden of aligning substance with value creation did not prevent taxpayers from migrating to low-tax jurisdictions. However, the global minimum tax rate imposed by the OECD’s Global Anti-Based Erosion (GloBE) Model Rules is currently leveling the playing field and preventing groups from keeping their group effective tax rate below such minimum. For commodity traders – especially for those with vertically integrated shipping activities – this is an opportunity to generate income not subject to the global minimum tax rules.


Summary

As the commodity trading landscape evolves, companies must monitor and update their transfer pricing practices to stay aligned with new operational dynamics and strategic shifts. With M&A trends, decarbonization efforts and AI integration reshaping the industry, a strategic equilibrium between financial success and innovation becomes crucial. Looking ahead, various factors, including market shifts and structural changes, demand the development of more sophisticated transfer pricing models for ensuring arm's length compliance and securing a competitive edge in a market that continues to rapidly transform.

Related articles

New Q&A on transfer pricing issued by the Swiss Federal Tax Administration

Additional transfer pricing guidance offers important insights into Swiss practice and the interpretation of international rules.

Spotlight on SFTA guidance regarding intercompany financial transactions

The transfer pricing Q&A provides welcome clarification of intercompany loans in the TP context.

New Swiss transfer pricing guidance

Additional guidance offers insights into the treatment of transfer pricing adjustments in Switzerland and their tax impact.

    About this article