Column : From Foxconn to Nokia, and more

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Sunil Jain : Feb 08 2013, 20:59 IST

The exact figures are a bit of a commercial secret, but Apple reportedly makes between $150 to $250 per iPad that Chinese assembler Foxconn makes for it. Foxconn, on the other hand, makes just a small fraction of this once you take out the cost of the goods it imports as part of the assembly process. A chart by Bloomberg puts Apple’s margins at 30% in 2012 as compared to Foxconn’s 1.5%—while Apple’s margins doubled since the iPhone debuted in June 2007, Bloomberg says, Foxconn’s nearly halved.

Now imagine what would happen, to Foxconn as well as to a host of other Chinese manufacturers, if the Chinese taxman were to slap a transfer pricing case on it and argue that a part of the profits Apple was making was nothing but underinvoicing of exports by Foxconn? Apple would think twice about getting manufacturing done by Foxconn, that’s what. Yet it appears that’s what the taxman in India is in the process of doing in the case of the mobile phones exported by Nokia from its assembly operations near Chennai—while a formal tax notice is yet to be served, those in the know say the tax demand is likely to be in the region of R13,000 crore.

The big difference between Foxconn and Nokia, of course, is that while the latter is a subsidiary of the parent Finnish firm, there are no ownership ties between Apple and Foxconn, but the principle is the same: how do you impute a fair value to the

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Paresh V | 08-Feb-2013Reply | Forward

Very apt article. Highly subjective and retrograde interpretations of guidelines has been the norm in Transfer pricing decisions by the TP officers all over India. Even when the software exports were tax free, they readjusted profits to ridiculous amounts, using non-transparent data available only to the department. They used the term that readjusted profit does not enjoy tax exemption in devious manner. All this is done in name of widening tax base and getting more revenue. It completely ignores the ill effect and uncertainty on business climate in the country.