NEW Corporation, based in Sydney, Australia, has a wholly owned subsidiary in Taiwan. The Taiwanese subsidiary manufactures bicycles at a cost of $20 per unit and sells the bicycles to NEW Corp at an FOB shipping point price of $100 each. NEW pays shipping costs of $10 per bicycle and an import duty of 10 percent on the $100 invoice price. NEW sells the bicycles in Australia for $200 each. The Australian tax authority discovers that NEW's Taiwanese subsidiary also sells its bicycles to uncontrolled Australian customers at a price of $80 each. Accordingly, Australian tax authority makes a transfer pricing adjustment to NEW's tax return that decreases NEW's cost of goods sold by $20 per bicycle. An offsetting adjustment (refund) is made for the import duty previously paid. The effective tax rate in Taiwan is 25 percent and in Australia is 36 percent.
Required
• Discuss NEW Corporations decision to allow its Taiwanese subsidiary to charge a higher price to NEW than to uncontrolled customers in Australia. Assess the likelihood that the Taiwanese tax authority will provide a correlative adjustment to NEW Corp.