A.L.M.T.
(Thailand) Co.,
Ltd.
Transfer pricing
report
For fiscal year ended 31 March
2014
Issued: 15 October 2014
This documentation is prepared in order to explain the Company’s transfer pricing
policy. The information contained in this documentation is strictly confidential and
must not be disclosed to any irrelevant parties.
Executive Summary
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC i
Executive Summary
The Transfer Pricing Report (hereinafter referred to as “the Report”) is prepared in order to present
details of the related-party transactions between A.L.M.T. (Thailand) Co., Ltd. (hereinafter referred to
as “ALTC”) and other companies in the Sumitomo Group which ALTC conducts transactions with. The
Report is also intended to provide supporting evidence that the transfer pricing practices of ALTC
have generated arm’s length operating profits consistent with the functions performed, assets
employed and the level of risks assumed.
To meet the objectives of the Report, PwC performed industry, company, functional, and economic
analyses to identify whether the operating results arising from the transfer pricing policies adopted by
ALTC are within the arm’s length range.
The Sumitomo Group is a multinational corporation and conglomerate based in Japan with a wide
range of products and services. Although each member of the Sumitomo Group is a company
established and developed with respect to the businesses of the Sumitomo Family, each company
under the Sumitomo Group operates “independently”. “Sumitomo Corporation” is only an English
name of the Sumitomo trading firm, not the name for the ultimate parent company. Each firm merely
cooperates with the others to support and manage the “Sumitomo” name and symbol they bear in
common.
One such business that the Sumitomo Group operates in is the electric industry. The ultimate parent
company of the Sumitomo Electric Group (hereinafter referred to as “the Group”) is Sumitomo
Electric Industries, Ltd. (hereinafter referred to as “SEI”). The Group includes 381 subsidiaries and
affiliates in more than 40 countries around the world1, mainly in Asia, North America, and Europe.
The Group consists of five business segments2, which are categorised by industry as follow: (1)
Automotive, (2) Infocommunications, (3) Electronics, (4) Environment and Energy, and (5) Industrial
Materials & Others.
ALTC is a subsidiary company which operates under the Sumitomo Electric Group and is held by its
intermediate parent company A.L.M.T. Corporation, Japan (“ALMT”). ALTC is manufacturer and
distributor of diamond dies, diamond wheel and cutting tools.
The industry analysis revealed that, the industrial equipment industry is characterised by high
product variety for different industries including drilling, refining and pipeline products for the oil
and natural gas sector; diesel engines, pumps and metal working machinery for the manufacturing
sector, etc. Despite this diversity, the industry's success is ultimately dependent on the level of
manufacturing activity and industrial production. During the recent recession, the world’s economy
experienced a severe contraction in manufacturing, while falling consumer spending led to fewer
manufacturing orders. This trend, in turn, led to less demand for both new machinery and industrial
equipment repairs and replacement parts. However, since 2010 the industry has been improving
considerably, due to resurgence in production through its primary markets.With respects to the
industrial equipment industry in Thailand, most cutting tools orders are injected into the automotive
and electronic industries. For the second half of the year 2012, production of automobiles accelerated,
owing mainly to domestic sales which benefited from pent-up demand and the government’s tax
rebate scheme for first-time car buyers, as well as due to temporary imports of parts and rapid
reconstruction of factories for business recovery from the flood in 2011. In 2012, hard disk drive
(“HDD”) industry, one of the electronic industries that require a huge number of cutting tools in its
production, was significantly affected markedly by the global economic downturn. During the last
quarter of 2012, there were signs of a recovery owing to better prospects of external demand.
1 http://global-sei.com/iv/annual/14/pdf/2014_all.pdf
2 http://global-sei.com/sei_info/org.html
Executive Summary
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC ii
ALTC’s main recurring transactions with related companies comprise of:
Transactions Related Parties TP Policy
T1 Purchase of raw materials and semifinished
products ADC, ODIA, ALDS Cost plus
T2 Purchase of finished products ALMT Resale price method
T3 Purchase of tools SUMIPOL, SHT Cost plus method
with negotiation
T4 Sale of manufactured products
T4.1 Sale of diamond wheels
ALAP(major
customer), SUMIPOL Resale price method
ALAP (smaller
customer), ADC Cost plus method
SHT
Comparable
uncontrolled price
method
T4.2 Sale of diamond dies ALAP, ADK Resale price method
T5 Royalty ADK, ADC Percentage of net
sales
T6 Receipt of services
T6.1 Receipt of management support services STHC Cost plus method
T6.2 Receipt of SEI Group IT infrastructure and
network services SEI Cost plus method
T6.3 Receipt of technical assistance and training
services ADC, ADK Cost plus method
T7 Receipt of loans STHC Cost plus method
According to the business model of the Group, ALTC must take into account the Group’s mission and
overall business plan in determining its own objectives and operating strategies. This includes the
Group’s objective to build a strong corporate flexibility responsive to the current business
environment and reinforce internal activities such as safety and environmental measures, quality
improvement, and cost reduction. To achieve this, ALTC attempts to customize the Group’s products
to meet the customers’ needs both locally and internationally.
The functional analysis reveals that ALTC operates under three main supply chains, namely i) the
manufacturing supply chain, ii) the manufacturing and distribution supply chain, and iii) the trading
supply chain. However, ALTC’s trading activities are considered minimal in amount (i.e. around 6% of
its total sales), which is insignificant when comparing to the Company’s entire business.
Under the aforementioned first two supply chains, all research and development functions are
conducted by other related companies. In addition, both ALTC and related companies also perform
production scheduling, manufacturing and inventory control in the two supply chains. ALTC and
other related companies also perform after-sales service in the manufacturing chain whereas only
ALTC is responsible for the function in the manufacturing and distribution supply chain. In addition,
only related companies perform sales and marketing and distribution function in the manufacturing
supply chain. In this regard, only ALTC performs distribution function in the manufacturing and
distribution supply chain.
Accordingly, other related companies absorb the R&D, inventory, production, product liability, and
foreign exchange risk in both supply chain. In addition, related companies are only liable to credit
risk in the manufacturing supply chain as they sell the Group’s product directly to third parties. In this
regard, ALTC assumes the risk associated with its manufacturing function in addition to market,
product liability and foreign exchange risk. ALTC also assumes credit risk in the manufacturing and
distribution supply chain as they conduct sales and distribution themselves.
Executive Summary
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC iii
Considering the assets employed under the two supply chains, ALTC owns no intangible assets such as
know-how and trademarks/trade names. However, both ALTC and other related companies owns
tangible asset such as manufacturing facilities.
The Transactional Net Margin Method (“TNMM”) was selected as the most appropriate method for
testing the operating results of ALTC. TNMM analysis starts with the search for potential companies
in order to find independent companies with similar functions, assets, and risk profiles as well as
economic circumstances as ALTC. After broad screening and detailed screening, 18 companies were
considered comparable independent companies to ALTC. The TNMM, applying the Profit Level
Indicator (“PLI”) of Return on Costs (“ROC”), reveals the following results:
* PLI of ALTC is five-year weighted average results from 2009-2013.
** PLI of comparable independent companies are five-year weighted average results from 2008-2012.
The TNMM analysis revealed that the five-year weighted average unadjusted ROC of comparable
independent companies range from 4.95% to 14.95% with the median of 9.05%. ALTC’s five-year
weighted average unadjusted ROC was 9.56%, which fall within the arm’s length range.
Profit Level
Indicators
ALTC’s
Operating
Results*
Comparable independent companies**
Lower Quartile Median Upper Quartile
Unadjusted Return on
Costs (“ROC”) 9.56 4.95 9.05 14.95
Table of Contents
Table of Contents
1. Introduction 6
1.1. Objective and Scope 7
1.2. Use of the Report 7
1.3. Limitations 7
1.4. Sources of Information 7
2. Overview of Sumitomo Group 9
2.3. Overview of ALMT 12
2.4. Overview of ALTC 12
2.5. Business model of Sumitomo Electric Group and ALTC 13
2.6. Operating Nature of Related Companies 15
2.6.1. A.L.M.T. Corporation (“ALMT”) 15
2.6.2. A.L.M.T. Diamond Corporation (“ADC”) 15
2.6.3. A.L.M.T. Asia Pacific Pte. Ltd. (“ALAP”) 15
2.6.4. Awaji Diamond Industrial Co., Ltd. (“ADK”) 15
2.6.5. ODIA Corporation (“ODIA”) 15
2.6.6. A.L.M.T. Diamond Dies (Suzhou) Co., Ltd. (“ALDS”) 16
2.6.7. SUMIPOL Co., Ltd. (“SUMIPOL”) 16
2.6.8. Sumi
A.L.M.T.
(Thailand) Co.,
Ltd.
Transfer pricing
report
For fiscal year ended 31 March
2014
Issued: 15 October 2014
This documentation is prepared in order to explain the Company’s transfer pricing
policy. The information contained in this documentation is strictly confidential and
must not be disclosed to any irrelevant parties.
Executive Summary
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC i
Executive Summary
The Transfer Pricing Report (hereinafter referred to as “the Report”) is prepared in order to present
details of the related-party transactions between A.L.M.T. (Thailand) Co., Ltd. (hereinafter referred to
as “ALTC”) and other companies in the Sumitomo Group which ALTC conducts transactions with. The
Report is also intended to provide supporting evidence that the transfer pricing practices of ALTC
have generated arm’s length operating profits consistent with the functions performed, assets
employed and the level of risks assumed.
To meet the objectives of the Report, PwC performed industry, company, functional, and economic
analyses to identify whether the operating results arising from the transfer pricing policies adopted by
ALTC are within the arm’s length range.
The Sumitomo Group is a multinational corporation and conglomerate based in Japan with a wide
range of products and services. Although each member of the Sumitomo Group is a company
established and developed with respect to the businesses of the Sumitomo Family, each company
under the Sumitomo Group operates “independently”. “Sumitomo Corporation” is only an English
name of the Sumitomo trading firm, not the name for the ultimate parent company. Each firm merely
cooperates with the others to support and manage the “Sumitomo” name and symbol they bear in
common.
One such business that the Sumitomo Group operates in is the electric industry. The ultimate parent
company of the Sumitomo Electric Group (hereinafter referred to as “the Group”) is Sumitomo
Electric Industries, Ltd. (hereinafter referred to as “SEI”). The Group includes 381 subsidiaries and
affiliates in more than 40 countries around the world1, mainly in Asia, North America, and Europe.
The Group consists of five business segments2, which are categorised by industry as follow: (1)
Automotive, (2) Infocommunications, (3) Electronics, (4) Environment and Energy, and (5) Industrial
Materials & Others.
ALTC is a subsidiary company which operates under the Sumitomo Electric Group and is held by its
intermediate parent company A.L.M.T. Corporation, Japan (“ALMT”). ALTC is manufacturer and
distributor of diamond dies, diamond wheel and cutting tools.
The industry analysis revealed that, the industrial equipment industry is characterised by high
product variety for different industries including drilling, refining and pipeline products for the oil
and natural gas sector; diesel engines, pumps and metal working machinery for the manufacturing
sector, etc. Despite this diversity, the industry's success is ultimately dependent on the level of
manufacturing activity and industrial production. During the recent recession, the world’s economy
experienced a severe contraction in manufacturing, while falling consumer spending led to fewer
manufacturing orders. This trend, in turn, led to less demand for both new machinery and industrial
equipment repairs and replacement parts. However, since 2010 the industry has been improving
considerably, due to resurgence in production through its primary markets.With respects to the
industrial equipment industry in Thailand, most cutting tools orders are injected into the automotive
and electronic industries. For the second half of the year 2012, production of automobiles accelerated,
owing mainly to domestic sales which benefited from pent-up demand and the government’s tax
rebate scheme for first-time car buyers, as well as due to temporary imports of parts and rapid
reconstruction of factories for business recovery from the flood in 2011. In 2012, hard disk drive
(“HDD”) industry, one of the electronic industries that require a huge number of cutting tools in its
production, was significantly affected markedly by the global economic downturn. During the last
quarter of 2012, there were signs of a recovery owing to better prospects of external demand.
1 http://global-sei.com/iv/annual/14/pdf/2014_all.pdf
2 http://global-sei.com/sei_info/org.html
Executive Summary
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC ii
ALTC’s main recurring transactions with related companies comprise of:
Transactions Related Parties TP Policy
T1 Purchase of raw materials and semifinished
products ADC, ODIA, ALDS Cost plus
T2 Purchase of finished products ALMT Resale price method
T3 Purchase of tools SUMIPOL, SHT Cost plus method
with negotiation
T4 Sale of manufactured products
T4.1 Sale of diamond wheels
ALAP(major
customer), SUMIPOL Resale price method
ALAP (smaller
customer), ADC Cost plus method
SHT
Comparable
uncontrolled price
method
T4.2 Sale of diamond dies ALAP, ADK Resale price method
T5 Royalty ADK, ADC Percentage of net
sales
T6 Receipt of services
T6.1 Receipt of management support services STHC Cost plus method
T6.2 Receipt of SEI Group IT infrastructure and
network services SEI Cost plus method
T6.3 Receipt of technical assistance and training
services ADC, ADK Cost plus method
T7 Receipt of loans STHC Cost plus method
According to the business model of the Group, ALTC must take into account the Group’s mission and
overall business plan in determining its own objectives and operating strategies. This includes the
Group’s objective to build a strong corporate flexibility responsive to the current business
environment and reinforce internal activities such as safety and environmental measures, quality
improvement, and cost reduction. To achieve this, ALTC attempts to customize the Group’s products
to meet the customers’ needs both locally and internationally.
The functional analysis reveals that ALTC operates under three main supply chains, namely i) the
manufacturing supply chain, ii) the manufacturing and distribution supply chain, and iii) the trading
supply chain. However, ALTC’s trading activities are considered minimal in amount (i.e. around 6% of
its total sales), which is insignificant when comparing to the Company’s entire business.
Under the aforementioned first two supply chains, all research and development functions are
conducted by other related companies. In addition, both ALTC and related companies also perform
production scheduling, manufacturing and inventory control in the two supply chains. ALTC and
other related companies also perform after-sales service in the manufacturing chain whereas only
ALTC is responsible for the function in the manufacturing and distribution supply chain. In addition,
only related companies perform sales and marketing and distribution function in the manufacturing
supply chain. In this regard, only ALTC performs distribution function in the manufacturing and
distribution supply chain.
Accordingly, other related companies absorb the R&D, inventory, production, product liability, and
foreign exchange risk in both supply chain. In addition, related companies are only liable to credit
risk in the manufacturing supply chain as they sell the Group’s product directly to third parties. In this
regard, ALTC assumes the risk associated with its manufacturing function in addition to market,
product liability and foreign exchange risk. ALTC also assumes credit risk in the manufacturing and
distribution supply chain as they conduct sales and distribution themselves.
Executive Summary
A.L.M.T. (Thailand) Co., Ltd. - Transfer pricing report
PwC iii
Considering the assets employed under the two supply chains, ALTC owns no intangible assets such as
know-how and trademarks/trade names. However, both ALTC and other related companies owns
tangible asset such as manufacturing facilities.
The Transactional Net Margin Method (“TNMM”) was selected as the most appropriate method for
testing the operating results of ALTC. TNMM analysis starts with the search for potential companies
in order to find independent companies with similar functions, assets, and risk profiles as well as
economic circumstances as ALTC. After broad screening and detailed screening, 18 companies were
considered comparable independent companies to ALTC. The TNMM, applying the Profit Level
Indicator (“PLI”) of Return on Costs (“ROC”), reveals the following results:
* PLI of ALTC is five-year weighted average results from 2009-2013.
** PLI of comparable independent companies are five-year weighted average results from 2008-2012.
The TNMM analysis revealed that the five-year weighted average unadjusted ROC of comparable
independent companies range from 4.95% to 14.95% with the median of 9.05%. ALTC’s five-year
weighted average unadjusted ROC was 9.56%, which fall within the arm’s length range.
Profit Level
Indicators
ALTC’s
Operating
Results*
Comparable independent companies**
Lower Quartile Median Upper Quartile
Unadjusted Return on
Costs (“ROC”) 9.56 4.95 9.05 14.95
Table of Contents
Table of Contents
1. Introduction 6
1.1. Objective and Scope 7
1.2. Use of the Report 7
1.3. Limitations 7
1.4. Sources of Information 7
2. Overview of Sumitomo Group 9
2.3. Overview of ALMT 12
2.4. Overview of ALTC 12
2.5. Business model of Sumitomo Electric Group and ALTC 13
2.6. Operating Nature of Related Companies 15
2.6.1. A.L.M.T. Corporation (“ALMT”) 15
2.6.2. A.L.M.T. Diamond Corporation (“ADC”) 15
2.6.3. A.L.M.T. Asia Pacific Pte. Ltd. (“ALAP”) 15
2.6.4. Awaji Diamond Industrial Co., Ltd. (“ADK”) 15
2.6.5. ODIA Corporation (“ODIA”) 15
2.6.6. A.L.M.T. Diamond Dies (Suzhou) Co., Ltd. (“ALDS”) 16
2.6.7. SUMIPOL Co., Ltd. (“SUMIPOL”) 16
2.6.8. Sumi
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