5. Function, Risk, and Asset
Analysis
A function, risk and asset analysis aims to determine how the business activities are organised within
a multinational group and to identify the value-adding activities in the business’s supply chain. The
outcome of a function, risk and asset analysis serves as a basis for characterising the contribution of
each entity to an intra-group transaction. Thus, an assessment of the functions performed, risks
assumed and assets employed by the entities involved in an intra-group transaction is critical to
determine the arm’s-length price of the related party transaction. This section provides an overview of
the functions performed, the risks assumed and the assets employed by the group entities involved in
the transactions under review.
As mentioned earlier, given insignificant amount of trading business, ALTC’s trading supply chain will
not be included in the analysis. The functional analysis, therefore, contains;
1) Manufacturing supply chain, and
2) Manufacturing and distribution supply chain.
There are certain functions that ALTC performs identically among these two supply chains. Therefore,
some sections of the functional profile below would discuss both supply chains concurrently. The
discussion of the functional profile by supply chain would be only provided where applicable.
5.1. Analysis of Functions, Risks, and Assets
The functional profile of ALTC vis-à-vis related parties participating in the supply chains is described
below.
5.1.1. Functions
Functions are defined as the activities and responsibilities of each entity in the supply chain. This
section discusses how the activities are allocated among the group companies under the supply chains
in which ALTC participates.
5.1.1.1. Research and development
Research and development (R&D) has always been one of the most important factors contributing to
the success of the Group. The Group believes that the product design, technology and innovation are
vital for the Group to maintain the customer’s expectations and its standing in the market. Therefore,
research and development is given great importance in this organisation.
ADC and ADK are responsible for R&D of new products and technological breakthrough, such as
designs and prototypes development as well as the R&D of the machinery and equipment used in
production. Those parties make strategic decisions on what type of research and development project
to be undertaken, required budget, etc., and bears all the cost incurred form research and
development activities.
As such, ADC and ADK are solely responsible for R&D function.
Function, Risk, and Asset Analysis
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC 38
5.1.1.2. Procurement of raw materials
The procurement of raw materials involves the setting of specifications for the raw materials, the
selection of suppliers, and the establishment of the expected quantity of raw materials used and the
quality control standards for the raw materials.
In general, the procurement function of raw materials can be separated into two types:
(i) Main raw materials, and
(ii) Consumable raw materials
Regarding the selection of suppliers, for main raw materials, ALMT has to get approval from the
parent company on the suppliers to purchase from. On the other hand, ALTC, without approval, can
select the suppliers itself when purchasing consumable raw materials.
For both types of raw materials, the parent company as the owner of the technology is the one to
provide the specifications of the materials to be used. ALMT then needs to follows the specification
guidelines when procuring for the raw materials.
Therefore, ALMT who sets raw materials specifications, and grants approvals on the suppliers to
purchase main raw materials from is the primary performer of this function. ALTC is considered
preforming the function secondarily.
5.1.1.3. Procurement of machinery and production equipment
The procurement of production equipment includes the setting of specifications for the production
equipment, the determination of budgets as well as the selection of suppliers. This function aims to
replace idle equipment, or to expand production output or product mix.
ADC and ADK, as the owners of the technology, determine the specification for the production
machinery and equipment to be used in the Group’s production process. ALTC can sources the
production equipment itself, but still has to follow the specification guidelines provided by ADC and
ADK. Nonetheless, ALTC is required to get approval from the parent company when the price of
equipment to be purchased exceeds JPY 10 million.
It can be concluded that the related parties perform this function primarily, while ALTC takes a
secondary role on this function.
5.1.1.4. Production scheduling
Production scheduling is conducted to control the timing and flow of raw material/parts purchases
and the production schedule in order to meet customers’ delivery requirements. It ensures that the
products are available to the market on a timely basis.
ALTC is responsible for day-to-day production planning and plant scheduling based on the purchased
orders from customers. ALTC updates the estimated orders on annual and monthly basis to examine
its performance and minimize the impact of material fluctuations and demand for the products. The
revision of estimated orders allows ALTC to modify its production appropriately and monitor the
quantity of finished goods, thereby keeping a proper amount of required inventory. Other related
manufacturers supplying raw materials to ALTC are also responsible for their own production
scheduling.
Therefore, ALTC and other related manufacturers are responsible for planning their own production
schedules.
Function, Risk, and Asset Analysis
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC 39
5.1.1.5. Manufacturing
Production process deals with the production of raw materials into finished goods.
Under both supply chains, ALTC is responsible for manufacturing diamond wheels, diamond dies, and
cutting tools supplying to related and third parties customers. Other related entities also involve in the
manufacturing function with respect to raw materials supplied to ALTC for the production.
Thus, both ALTC and related entities are responsible for manufacturing function.
5.1.1.6. Inventory control
The inventory control function involves monitoring, determining, and controlling the stock levels of
raw materials/parts and finished goods maintained in the warehouses. Inventory control function can
be divided into two main categories, i.e. raw material inventory control and finished goods inventory
control.
5.1.1.6.1. Raw material control
ALTC determines the quantity of raw materials to be stored and used for its production process. Once
the raw materials are delivered to ALTC, they are stored at ALTC’s warehouse for approximately one
and half month for diamond dies and three months for diamond wheels prior to the production. Other
related companies are also responsible for maintaining raw material inventory at their own
warehouses and determine their own safety stock level at their own risk.
Therefore, both ALTC and other related entities are responsible for the raw material inventory control
functions.
5.1.1.6.2. Finished products
Manufacturing supply chain
ALTC’s finished goods are delivered to related parties customers right after the completion of the
production and quality check processes. On the other hand, related parties who purchase the products
from ALTC is responsible for controlling their own inventories.
As such, ALTC has no responsibility in the finished product inventory control, while other related
parties are performing the function.
Manufacturing and distribution supply chain
ALTC normally ships the products instantly after the production. However, ALTC stores the finished
products supplied to Hoya Optics (Thailand) Co., Ltd., an unrelated party customer for about 1 month
prior to the delivery. Nevertheless, the amount of transaction is relatively small comparing to the
entire sales amount. Other related parties do not perform finished product inventory control under
this supply chain. This is due to the fact that the sale transactions and delivery are made entirely to
unrelated party customers.
5.1.1.7. Quality control
Quality control is the control of the standards or quality of raw materials/ parts, machinery and
equipment, finished products and manufacturing processes. It is carried out to ensure that the quality
of the products meets the standards required by customers. The quality control function involves
setting quality control standards and conducting quality control activities.
Function, Risk, and Asset Analysis
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC 40
Because production intellectual properties (“IPs”) are owned by other related parties, those companies
establish the quality control standards of raw materials, finished products as well as manufacturing
process to ensure that the quality meets with the standards required by customers.
Under both supply chains, ALTC undertakes quality control procedures according to the standards set
by the IPs owners. In this regards, ALTC conducts quality control testing procedures on finished
products before delivery to customers to ensure that the products meet the Group standards. Other
related parties are also involved in quality control activities with respect to their own production.
In conclusion, related parties are primarily responsible for quality control function while ALTC takes
on a secondary role.
5.1.1.8. Sale and marketing
The sale and marketing functions comprise assessing market trends, determining marketing strategies,
setting marketing budgets/expenses, visiting customers in order to secure orders, selling products,
negotiating s
5. Function, Risk, and Asset
Analysis
A function, risk and asset analysis aims to determine how the business activities are organised within
a multinational group and to identify the value-adding activities in the business’s supply chain. The
outcome of a function, risk and asset analysis serves as a basis for characterising the contribution of
each entity to an intra-group transaction. Thus, an assessment of the functions performed, risks
assumed and assets employed by the entities involved in an intra-group transaction is critical to
determine the arm’s-length price of the related party transaction. This section provides an overview of
the functions performed, the risks assumed and the assets employed by the group entities involved in
the transactions under review.
As mentioned earlier, given insignificant amount of trading business, ALTC’s trading supply chain will
not be included in the analysis. The functional analysis, therefore, contains;
1) Manufacturing supply chain, and
2) Manufacturing and distribution supply chain.
There are certain functions that ALTC performs identically among these two supply chains. Therefore,
some sections of the functional profile below would discuss both supply chains concurrently. The
discussion of the functional profile by supply chain would be only provided where applicable.
5.1. Analysis of Functions, Risks, and Assets
The functional profile of ALTC vis-à-vis related parties participating in the supply chains is described
below.
5.1.1. Functions
Functions are defined as the activities and responsibilities of each entity in the supply chain. This
section discusses how the activities are allocated among the group companies under the supply chains
in which ALTC participates.
5.1.1.1. Research and development
Research and development (R&D) has always been one of the most important factors contributing to
the success of the Group. The Group believes that the product design, technology and innovation are
vital for the Group to maintain the customer’s expectations and its standing in the market. Therefore,
research and development is given great importance in this organisation.
ADC and ADK are responsible for R&D of new products and technological breakthrough, such as
designs and prototypes development as well as the R&D of the machinery and equipment used in
production. Those parties make strategic decisions on what type of research and development project
to be undertaken, required budget, etc., and bears all the cost incurred form research and
development activities.
As such, ADC and ADK are solely responsible for R&D function.
Function, Risk, and Asset Analysis
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC 38
5.1.1.2. Procurement of raw materials
The procurement of raw materials involves the setting of specifications for the raw materials, the
selection of suppliers, and the establishment of the expected quantity of raw materials used and the
quality control standards for the raw materials.
In general, the procurement function of raw materials can be separated into two types:
(i) Main raw materials, and
(ii) Consumable raw materials
Regarding the selection of suppliers, for main raw materials, ALMT has to get approval from the
parent company on the suppliers to purchase from. On the other hand, ALTC, without approval, can
select the suppliers itself when purchasing consumable raw materials.
For both types of raw materials, the parent company as the owner of the technology is the one to
provide the specifications of the materials to be used. ALMT then needs to follows the specification
guidelines when procuring for the raw materials.
Therefore, ALMT who sets raw materials specifications, and grants approvals on the suppliers to
purchase main raw materials from is the primary performer of this function. ALTC is considered
preforming the function secondarily.
5.1.1.3. Procurement of machinery and production equipment
The procurement of production equipment includes the setting of specifications for the production
equipment, the determination of budgets as well as the selection of suppliers. This function aims to
replace idle equipment, or to expand production output or product mix.
ADC and ADK, as the owners of the technology, determine the specification for the production
machinery and equipment to be used in the Group’s production process. ALTC can sources the
production equipment itself, but still has to follow the specification guidelines provided by ADC and
ADK. Nonetheless, ALTC is required to get approval from the parent company when the price of
equipment to be purchased exceeds JPY 10 million.
It can be concluded that the related parties perform this function primarily, while ALTC takes a
secondary role on this function.
5.1.1.4. Production scheduling
Production scheduling is conducted to control the timing and flow of raw material/parts purchases
and the production schedule in order to meet customers’ delivery requirements. It ensures that the
products are available to the market on a timely basis.
ALTC is responsible for day-to-day production planning and plant scheduling based on the purchased
orders from customers. ALTC updates the estimated orders on annual and monthly basis to examine
its performance and minimize the impact of material fluctuations and demand for the products. The
revision of estimated orders allows ALTC to modify its production appropriately and monitor the
quantity of finished goods, thereby keeping a proper amount of required inventory. Other related
manufacturers supplying raw materials to ALTC are also responsible for their own production
scheduling.
Therefore, ALTC and other related manufacturers are responsible for planning their own production
schedules.
Function, Risk, and Asset Analysis
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC 39
5.1.1.5. Manufacturing
Production process deals with the production of raw materials into finished goods.
Under both supply chains, ALTC is responsible for manufacturing diamond wheels, diamond dies, and
cutting tools supplying to related and third parties customers. Other related entities also involve in the
manufacturing function with respect to raw materials supplied to ALTC for the production.
Thus, both ALTC and related entities are responsible for manufacturing function.
5.1.1.6. Inventory control
The inventory control function involves monitoring, determining, and controlling the stock levels of
raw materials/parts and finished goods maintained in the warehouses. Inventory control function can
be divided into two main categories, i.e. raw material inventory control and finished goods inventory
control.
5.1.1.6.1. Raw material control
ALTC determines the quantity of raw materials to be stored and used for its production process. Once
the raw materials are delivered to ALTC, they are stored at ALTC’s warehouse for approximately one
and half month for diamond dies and three months for diamond wheels prior to the production. Other
related companies are also responsible for maintaining raw material inventory at their own
warehouses and determine their own safety stock level at their own risk.
Therefore, both ALTC and other related entities are responsible for the raw material inventory control
functions.
5.1.1.6.2. Finished products
Manufacturing supply chain
ALTC’s finished goods are delivered to related parties customers right after the completion of the
production and quality check processes. On the other hand, related parties who purchase the products
from ALTC is responsible for controlling their own inventories.
As such, ALTC has no responsibility in the finished product inventory control, while other related
parties are performing the function.
Manufacturing and distribution supply chain
ALTC normally ships the products instantly after the production. However, ALTC stores the finished
products supplied to Hoya Optics (Thailand) Co., Ltd., an unrelated party customer for about 1 month
prior to the delivery. Nevertheless, the amount of transaction is relatively small comparing to the
entire sales amount. Other related parties do not perform finished product inventory control under
this supply chain. This is due to the fact that the sale transactions and delivery are made entirely to
unrelated party customers.
5.1.1.7. Quality control
Quality control is the control of the standards or quality of raw materials/ parts, machinery and
equipment, finished products and manufacturing processes. It is carried out to ensure that the quality
of the products meets the standards required by customers. The quality control function involves
setting quality control standards and conducting quality control activities.
Function, Risk, and Asset Analysis
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC 40
Because production intellectual properties (“IPs”) are owned by other related parties, those companies
establish the quality control standards of raw materials, finished products as well as manufacturing
process to ensure that the quality meets with the standards required by customers.
Under both supply chains, ALTC undertakes quality control procedures according to the standards set
by the IPs owners. In this regards, ALTC conducts quality control testing procedures on finished
products before delivery to customers to ensure that the products meet the Group standards. Other
related parties are also involved in quality control activities with respect to their own production.
In conclusion, related parties are primarily responsible for quality control function while ALTC takes
on a secondary role.
5.1.1.8. Sale and marketing
The sale and marketing functions comprise assessing market trends, determining marketing strategies,
setting marketing budgets/expenses, visiting customers in order to secure orders, selling products,
negotiating s
การแปล กรุณารอสักครู่..
5. Function, Risk, and Asset
Analysis
A function, risk and asset analysis aims to determine how the business activities are organised within
a multinational group and to identify the value-adding activities in the business’s supply chain. The
outcome of a function, risk and asset analysis serves as a basis for characterising the contribution of
each entity to an intra-group transaction. Thus, an assessment of the functions performed, risks
assumed and assets employed by the entities involved in an intra-group transaction is critical to
determine the arm’s-length price of the related party transaction. This section provides an overview of
the functions performed, the risks assumed and the assets employed by the group entities involved in
the transactions under review.
As mentioned earlier, given insignificant amount of trading business, ALTC’s trading supply chain will
not be included in the analysis. The functional analysis, therefore, contains;
1) Manufacturing supply chain, and
2) Manufacturing and distribution supply chain.
There are certain functions that ALTC performs identically among these two supply chains. Therefore,
some sections of the functional profile below would discuss both supply chains concurrently. The
discussion of the functional profile by supply chain would be only provided where applicable.
5.1. Analysis of Functions, Risks, and Assets
The functional profile of ALTC vis-à-vis related parties participating in the supply chains is described
below.
5.1.1. Functions
Functions are defined as the activities and responsibilities of each entity in the supply chain. This
section discusses how the activities are allocated among the group companies under the supply chains
in which ALTC participates.
5.1.1.1. Research and development
Research and development (R&D) has always been one of the most important factors contributing to
the success of the Group. The Group believes that the product design, technology and innovation are
vital for the Group to maintain the customer’s expectations and its standing in the market. Therefore,
research and development is given great importance in this organisation.
ADC and ADK are responsible for R&D of new products and technological breakthrough, such as
designs and prototypes development as well as the R&D of the machinery and equipment used in
production. Those parties make strategic decisions on what type of research and development project
to be undertaken, required budget, etc., and bears all the cost incurred form research and
development activities.
As such, ADC and ADK are solely responsible for R&D function.
Function, Risk, and Asset Analysis
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC 38
5.1.1.2. Procurement of raw materials
The procurement of raw materials involves the setting of specifications for the raw materials, the
selection of suppliers, and the establishment of the expected quantity of raw materials used and the
quality control standards for the raw materials.
In general, the procurement function of raw materials can be separated into two types:
(i) Main raw materials, and
(ii) Consumable raw materials
Regarding the selection of suppliers, for main raw materials, ALMT has to get approval from the
parent company on the suppliers to purchase from. On the other hand, ALTC, without approval, can
select the suppliers itself when purchasing consumable raw materials.
For both types of raw materials, the parent company as the owner of the technology is the one to
provide the specifications of the materials to be used. ALMT then needs to follows the specification
guidelines when procuring for the raw materials.
Therefore, ALMT who sets raw materials specifications, and grants approvals on the suppliers to
purchase main raw materials from is the primary performer of this function. ALTC is considered
preforming the function secondarily.
5.1.1.3. Procurement of machinery and production equipment
The procurement of production equipment includes the setting of specifications for the production
equipment, the determination of budgets as well as the selection of suppliers. This function aims to
replace idle equipment, or to expand production output or product mix.
ADC and ADK, as the owners of the technology, determine the specification for the production
machinery and equipment to be used in the Group’s production process. ALTC can sources the
production equipment itself, but still has to follow the specification guidelines provided by ADC and
ADK. Nonetheless, ALTC is required to get approval from the parent company when the price of
equipment to be purchased exceeds JPY 10 million.
It can be concluded that the related parties perform this function primarily, while ALTC takes a
secondary role on this function.
5.1.1.4. Production scheduling
Production scheduling is conducted to control the timing and flow of raw material/parts purchases
and the production schedule in order to meet customers’ delivery requirements. It ensures that the
products are available to the market on a timely basis.
ALTC is responsible for day-to-day production planning and plant scheduling based on the purchased
orders from customers. ALTC updates the estimated orders on annual and monthly basis to examine
its performance and minimize the impact of material fluctuations and demand for the products. The
revision of estimated orders allows ALTC to modify its production appropriately and monitor the
quantity of finished goods, thereby keeping a proper amount of required inventory. Other related
manufacturers supplying raw materials to ALTC are also responsible for their own production
scheduling.
Therefore, ALTC and other related manufacturers are responsible for planning their own production
schedules.
Function, Risk, and Asset Analysis
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC 39
5.1.1.5. Manufacturing
Production process deals with the production of raw materials into finished goods.
Under both supply chains, ALTC is responsible for manufacturing diamond wheels, diamond dies, and
cutting tools supplying to related and third parties customers. Other related entities also involve in the
manufacturing function with respect to raw materials supplied to ALTC for the production.
Thus, both ALTC and related entities are responsible for manufacturing function.
5.1.1.6. Inventory control
The inventory control function involves monitoring, determining, and controlling the stock levels of
raw materials/parts and finished goods maintained in the warehouses. Inventory control function can
be divided into two main categories, i.e. raw material inventory control and finished goods inventory
control.
5.1.1.6.1. Raw material control
ALTC determines the quantity of raw materials to be stored and used for its production process. Once
the raw materials are delivered to ALTC, they are stored at ALTC’s warehouse for approximately one
and half month for diamond dies and three months for diamond wheels prior to the production. Other
related companies are also responsible for maintaining raw material inventory at their own
warehouses and determine their own safety stock level at their own risk.
Therefore, both ALTC and other related entities are responsible for the raw material inventory control
functions.
5.1.1.6.2. Finished products
Manufacturing supply chain
ALTC’s finished goods are delivered to related parties customers right after the completion of the
production and quality check processes. On the other hand, related parties who purchase the products
from ALTC is responsible for controlling their own inventories.
As such, ALTC has no responsibility in the finished product inventory control, while other related
parties are performing the function.
Manufacturing and distribution supply chain
ALTC normally ships the products instantly after the production. However, ALTC stores the finished
products supplied to Hoya Optics (Thailand) Co., Ltd., an unrelated party customer for about 1 month
prior to the delivery. Nevertheless, the amount of transaction is relatively small comparing to the
entire sales amount. Other related parties do not perform finished product inventory control under
this supply chain. This is due to the fact that the sale transactions and delivery are made entirely to
unrelated party customers.
5.1.1.7. Quality control
Quality control is the control of the standards or quality of raw materials/ parts, machinery and
equipment, finished products and manufacturing processes. It is carried out to ensure that the quality
of the products meets the standards required by customers. The quality control function involves
setting quality control standards and conducting quality control activities.
Function, Risk, and Asset Analysis
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC 40
Because production intellectual properties (“IPs”) are owned by other related parties, those companies
establish the quality control standards of raw materials, finished products as well as manufacturing
process to ensure that the quality meets with the standards required by customers.
Under both supply chains, ALTC undertakes quality control procedures according to the standards set
by the IPs owners. In this regards, ALTC conducts quality control testing procedures on finished
products before delivery to customers to ensure that the products meet the Group standards. Other
related parties are also involved in quality control activities with respect to their own production.
In conclusion, related parties are primarily responsible for quality control function while ALTC takes
on a secondary role.
5.1.1.8. Sale and marketing
The sale and marketing functions comprise assessing market trends, determining marketing strategies,
setting marketing budgets/expenses, visiting customers in order to secure orders, selling products,
negotiating s
การแปล กรุณารอสักครู่..