ACCT650 Unit 5 Final Paper

docx

School

Colorado Technical University *

*We aren’t endorsed by this school

Course

650

Subject

Business

Date

Feb 20, 2024

Type

docx

Pages

20

Uploaded by BrigadierRockAnt93

Report
HP CASE STUDY Hewlett-Packard (HP) Case Study Domonique Jones Professor: Wendy Aoki ACCT650-2304B-99 MBA Capstone 10/29/2023
HP CASE STUDY Abstract In this research paper, I will discuss the entire accounting cycle and conduct a financial analysis. I will summarize the findings and then proceed to further analyze the financial ratios and trends to make informed management decisions. Additionally, I will evaluate a growth or improvement opportunity for the company and determine whether it should be accepted or rejected by the organization. To increase profitability, I will create a strategic plan that includes an analysis of financial information and recommendations. This plan will also evaluate risks and opportunities, as well as alternatives to the proposed strategy. Furthermore, I will provide an overview of the historical regulations of the Internal Revenue Service (IRS) regarding income allocation and deductions, with a specific focus on multinational corporations (MNCs). Alongside this, I will present a report on two companies that have faced accusations of illegal price transfer or income allocation. To assist management in conducting business with overseas subsidiaries without issues with the IRS, I will offer guidance. Lastly, I will develop an audit program presentation utilizing relevant financial and operational data provided in the case study.
HP CASE STUDY Hewlett-Packard (HP) Case Study The accounting cycle involves a series of stages beginning with the documentation of business transactions and culminating in the creation of financial statements. This method embodies the objective behind financial accounting - to present economic information as comprehensive, useful statements. Essentially, recording transactions and tracking revenue and expenses aim to transform this data into meaningful financial insights by showcasing it through balance sheets, income statements, owner's equity statement and cash flow analysis. The process of the accounting cycle involves a series of steps that are repeated in a consistent pattern each period, and results in the preparation of financial statements. Some businesses opt to produce these statements quarterly, while others do so annually. Accordingly, companies completing this task every quarter complete four cycles per year whereas those who only prepare them once annually conduct one full cycle per year. Net Profit Margin After considering all expenses such as taxes, interest, and depreciation, the net overall revenue reflects profitability. A higher ratio indicates that the company is effectively generating sales and utilizing its resources. In this case, with a rate of 62%, it shows that the organization is exceeding expectations. Proft for Assets Also known as Return on Investment, the Return on Assets ratio is a crucial metric that assesses an organization's efficiency in managing and utilizing its asset investments to generate profits. A higher percentage indicates better performance in using assets to drive sales. However, our example shows only 19%, signifying inadequate utilization of resources by the company.
Your preview ends here
Eager to read complete document? Join bartleby learn and gain access to the full version
  • Access to all documents
  • Unlimited textbook solutions
  • 24/7 expert homework help
HP CASE STUDY Return Equity Perhaps the most vital financial ratio for investors in a company is the Return on Equity (ROE) proportion. It assesses how much profit the shareholders are earning from their investment in the company. A higher percentage generally implies that management is utilizing the investor’s money proficiently, aside from certain cases where it may not hold true. In this organization, ROE stands at 27%, implying reduced business activity within its operations. The liquidity ratio serves as an indicator of whether a company's existing resources will be sufficient to fulfill its obligations when they become due. The current ratio is a financial measure that indicates the amount of present assets versus existing liabilities. It serves as an indicator of a company's liquidity, where higher current assets to lower current liabilities suggest reliability in settling due obligations. Quick Ratio When the total amount of money, attractive securities and sales records are compared to current liabilities, a ratio greater than 1 indicates that the organization is in a stronger position. The money ratio is typically viewed as a more conservative measure of an organization's ability to meet its obligations compared to many other liquidity ratios. This is due in part to the fact that various assets, such as accounts receivable, are omitted from the calculation. If this value exceeds 1, it indicates that the company has adequate resources available for covering liabilities. In our example, with a ratio of 1.49, the organization appears well-positioned financially. Debt to Equity Ratio This considers the level of debt compared to equity generated in a company. If the ratio is too high, it suggests that owners are relying heavily on debt for business financing. This could
HP CASE STUDY become problematic if there isn't enough revenue to support interest payments. In our scenario, the ratio is 0.43 indicating that excessive debt usage is not an issue for this organization. The company's financial health provides a deeper understanding of its current situation and offers insights into its potential future. By examining ratios, trends, SWOT, and PEST analysis, as well as other tools, the accounting team and management can predict the company's future trajectory. This paper will explore the steps taken in this process and propose a plan to enhance both growth and profitability. Ratios Used Before proceeding with this paper, it would be prudent to review the ratios that were utilized last week to assess our current position and understand the insights provided by those ratios. The following are the specific ratios: Profitability Ratios Net Profit Margin Ratio = Net Income/Net Sales =134,196/215,800*100% = 62% Return on Assets = Net income/total assets = 134,196/713,871*100% = 19% Return on equity = NET INCOME/equity =134,196/494,196 = 27% Liquidity Ratios Current Ratio= CA/CL = 413,871/214,675 =1.93 Quick Ratio = quick assets/current liabilities = 379,000/214,675 = 1.77 Cash ratio= cash+securities/current liabilities = 318,931/214,675 = 1.49 Solvency Ratios Debt to equity ratio = debt/equity = 214,675/494,196 = 0.43 Equity ratio = equity/total assets = 494,196/713,871 = 0.69
HP CASE STUDY Beginning with profitability ratios, which indicate the company's ability to generate profit (Hayes, 2023), our return on assets is nearly 100%, signifying impressive profitability from our existing assets. Similarly, our profit margin, reflecting the proportion of profit earned from revenue, stands at a remarkable 62%, surpassing the recommended threshold of 20%. These higher-than-recommended figures demonstrate that we are achieving exceptional levels of profit. Next, we proceed to examine Liquidity ratios, which provide information about the ease with which our assets can be converted into cash to settle our debts without needing external funding (Hayes, 2023). The acid test ratio assesses the proportion of short-term assets compared to short-term liabilities and indicates how quickly these obligations could be met. With a ratio of 1.93, it is revealed that we possess more assets than liabilities, which is desirable. This ratio is also referred to as the quick ratio occasionally because it relies on the same data. Lastly, we evaluate the current ratio, which stands at 1.49, indicating that we have more current assets than current liabilities, signifying a favorable liquidity position. The solvency ratios, the final set of ratios we will examine, provide an overall assessment of a company's financial health by evaluating its cash flow and long-term obligations (Hayes, 2022). The initial ratio, called the debt-to-equity ratio, evaluates the relationship between debt and shareholders' equity by measuring their respective proportions. Currently, this ratio stands at 0.43%, meaning that almost half of our liabilities are financed through debt. To improve our financial standing, it would be beneficial to reduce this ratio. Another important ratio is the debt ratio, which compares total assets to total liabilities. Currently, this ratio is approximately 0.69%, indicating that our liabilities constitute around half of our assets. Growth or Improvement for Company
Your preview ends here
Eager to read complete document? Join bartleby learn and gain access to the full version
  • Access to all documents
  • Unlimited textbook solutions
  • 24/7 expert homework help
HP CASE STUDY As mentioned earlier, all the ratios indicate that our company is in good financial health. However, the solvency ratios indicate that there could be a potential problem with our long-term liabilities. If we can address this issue, we will be able to secure more funding for future growth opportunities. Currently, the only viable option for growth is through acquiring another company. To enhance our long-term obligations, our main objective should be to expedite their repayment. While we possess sufficient income to accomplish this, it will entail reallocating funds from other sources, potentially our stockholders' equity. The return on assets demonstrates that these long-term liabilities are yielding favorable returns and can be regarded as profitable investments for the company. Utilizing funds from stockholder equity may not be seen as a preferable option. Nevertheless, taking a long-term standpoint reveals that this decision would not only reduce our obligations - which is advantageous on its own - but also provide the opportunity to allocate more funds towards reinvesting in our company or acquiring another business to expand our brand. By using the funds presently to reduce our debts, we can generate additional income at an earlier stage. It would be illogical to pursue the acquisition of a company along with its debts, considering that our debts make up almost half of our revenue. Strategic Plan for Board of Directors In the next section, we will discuss our strategy to enhance our profitability, which will be presented to the board of directors. Profitability refers to reaching a stage where we generate earnings. The rationale behind prioritizing this aspect is that profit represents the remaining amount from our revenue after deducting all expenses, costs, and debts – essentially, it is what we ultimately earn.
HP CASE STUDY As previously mentioned, my focus is on reducing our liabilities, but this alone will only have a limited impact on our profitability. Another strategy to increase profitability is by introducing a new product onto the market. This will help generate interest from both existing and potential customers, strengthening our relationship with current customers who may upgrade and attracting customers away from our competitors. Additionally, by entering a new market with this product, we could expand our reach and potentially dominate that market as we have done in the computer industry. The potential drawbacks of this idea involve the significant financial investment required before generating any profit. This includes expenses for research, planning, development, and marketing, as well as costs for labor and materials. These steps consume time, meaning that money will be spent with no guarantee of seeing returns for possibly up to a year. Another risk to consider is the possibility of poor reception or lack of recognition in a new market if we choose to expand. We would only discover this after releasing the product, resulting in lost profits from all the investments made in investigation, strategizing, effort, resources, promotion, transportation, and various additional costs. The most effective strategy to achieve multiple goals - increasing profits, reducing long- term liabilities, and expanding our business - is to utilize our existing resources. This involves utilizing the equipment and materials we currently possess to create a limited number of prototypes. By doing so, we can avoid incurring additional liabilities while improving our return on assets and overall profitability. However, certain costs such as market research, wages, and marketing expenses would still need to be funded separately. On the bright side, other expenses would be shared with our existing products. Instead of immediately mass-producing the new items for an untested market, we would initially manufacture around 100,000 units to assess
HP CASE STUDY consumer interest. If the product proves successful, we can then ramp up production accordingly. If more materials or machinery are required, at least we can rely on incoming profits to cover these expenses. If the current plan still appears too risky, we can consider following the strategy adopted by other electronic companies, which is to release existing products. Profitability for companies such as Samsung, PlayStation, Xbox, and Apple have seen a rise through the reintroduction of products that already enjoy a loyal customer following. This approach requires less investment in research as there are usually minimal changes involved. Furthermore, as we would be substituting one item for another, there would be no need to concern ourselves with the materials and manpower required for the new product being re-released. However, a challenge with this idea is that none of the products on our current list generate significant excitement or buzz that would justify reintroducing them. Desktops, printers, and laptops are known for their durability, and typically we release new models instead of reissuing existing ones to improve and capitalize on advancements. In general, we have numerous choices available to enhance our profitability. We can opt for expansion, either within our existing market or by entering a new market through the relaunch of a product or the development of a new one. If these options seem attractive, we can streamline our approach and concentrate on reducing long-term liabilities. This strategy alone will boost profitability without incurring further debt or liabilities. However, it may take some time before we start witnessing a significant increase in profitability. Transfer ‘Mis’ Pricing Charges another subsidiary for goods or services transferred between them or parent company bills another connected subsidiary for rendering products or services. This can
Your preview ends here
Eager to read complete document? Join bartleby learn and gain access to the full version
  • Access to all documents
  • Unlimited textbook solutions
  • 24/7 expert homework help
HP CASE STUDY encompass physical items as well as intangible assets like intellectual property and trademarks. Although it may appear simple, multinational corporations have utilized this method to manipulate their tax payments on income generated by subsidiaries or the entire corporation. An approach utilized entails moving profits from a subsidiary situated in an area with steep corporate tax rates to another located in an area with a reduced corporate tax rate. This lets the organization evade paying all its assigned Corporate Income Tax, ultimately lowering their payment liability. There are several methods through which this can be achieved, and one of them is known as "mispricing." In this technique, one subsidiary either overcharges or undercharges for its products or services when selling to another related subsidiary. The purpose of this maneuver is to tamper with the financial statements to augment or reduce the taxable income disclosed by the affiliate. It should be emphasized that this act of fiddling with taxable income is unlawful and has emerged as a major concern on an international scale. US Transfer Pricing (Treasure Regulations 1.482-1) The calculation of taxable income for tangible goods in transfer pricing is governed by five approved approaches. Included in these methods are the Comparable Uncontrolled Method, Resale Price Method, Cost-Plus Method, Comparable Profits Method, and Profit Split method. To govern the suitable approach for a given transaction instance under consideration; it is essential to consider factors such as function performed on property or service delivered, contractual arrangements made between parties involved, economic conditions & risk associated with executing this activity successfully along with other aspects related to ownership rights over said assets/services rendered via agreement. It must be remembered that all these elements will ultimately influence price margins and profitability achieved through an arm's length exchange -
HP CASE STUDY where both sides can independently set their own terms without any undue influence from either side. To execute CUP effectively one needs to compare prices/ rates charged when transactions occur among companies/entities having no independent business relationship. This ensures greater transparency and fairness towards setting up competitive market parameters, ideally leading ideally also expedite future deals which are envisaged b/w closely held commercial entities optimizing financial outcomes while being legally compliant. The transfer pricing method known as resale price (RPM) determines the gross profit a distributor could earn from reselling an item. This figure is utilized to calculate decide on the suitable gross margin to be computed earned by a related subsidiary upon their resale of the same product. The cost-plus methodology involves computing a company's "cost-base" by factoring in fixed and variable expenses connected with manufacturing products or delivery services. A set markup percentage is added to this expense base, culminating in the final sales value that is used consistently for both connected and unconnected transactions. To following the arm's length principle, the transactional net margin method (TNMM) involves a comparison between "net profit" and an expense basis that would arise from a non-related deal and applying this identical net profit margin to a related transaction. The transfer pricing technique known as the comparable profit method evaluates whether a certain distance between parties is being upheld by comparing the effectiveness of related and unrelated transactions. If these transactions demonstrate similar levels of profitability, then it can be claimed that they conform to this basis. IRC Section 482 For Section 482 of the IRC to be considered valid, there are three prerequisites. 1. There must be at least two trades, businesses, or organizations involved.
HP CASE STUDY 2. Shared ownership or control, whether it be through direct means or indirectly, must exist among these entities. 3. To avoid the act of evading taxes or accurately exhibiting the revenue of relevant entities, it is necessary for the IRS to determine if an allocation is required. The IRC's section 482 necessitates that transnational or international company enterprises, who vend commodities or services to their related companies (namely subsidiaries/parents), must evaluate their tax responsibilities. This regulation reflects the arm's length pricing principle by demanding that a product/service retained cost by a subsidiary/fellow concern equals an unrelated company's transaction price for equivalent products/services in question. In situations where there is no analogous rate for such items, external firms' practices are popped into action so ascertaining balanced rates becomes feasible. The IRS regulation allows for the modification and redistribution of income, deductions, credits, and allowances among affiliated companies to ensure accurate representation. In doing so, the agency reserves the right to impose penalties as determined by its regulations. BEPS Action 13 The Action 13 of Base Erosion and Profit Shifting (BEPS) can be restated as follows: guideline necessitates that prominent global firms must produce a report on a country-by-country basis (CBC) containing information on income, profit distribution, tax payments as well as economic operations in all the jurisdictions they operate within (OECD.org, 2015). The reporting standard is aimed at augmenting transparency while submitting reports concerning revenue generation and commercial activity to relevant countries where these entities are involved. An approach consisting of three tiers has been implemented through the BEPS Action 13, which aims to standardize tax reporting (OECD.org, 2015). The first tier defines the key
Your preview ends here
Eager to read complete document? Join bartleby learn and gain access to the full version
  • Access to all documents
  • Unlimited textbook solutions
  • 24/7 expert homework help
HP CASE STUDY necessary information that should be incorporated in reports and accepted in a central database accessible by all relevant tax administrations (OECD.org). As per OECD.org, the reporting obligation in tier three mandates large multinational enterprises to furnish the annual financial performance report for every tax jurisdiction where their subordinate entities function. The statement should explicitly mention all revenue generated within these jurisdictions (OECD.org). Corporations failing to fulfill the documentation requirements and submit timely reports, as outlined in BEPS Action 13, will face penalties. These penalties may be imposed based on a set fee for each absent document or fiscal year being reviewed. Alternatively, they could also consider a percentage of adjusted income linked with non-compliant transactions or cross-border deal values that were either inadequately documented or not at all (OECD.org). Guidelines for transfer pricing (OECD) The OECD stands for the Organization for Economic Co-operation and Development. Has set standards that dictate how multinational entities should report their intangible property and services regarding transfer pricing. These regulations serve as a guidebook, outlining the necessary rules, reporting methods, and guidelines required of multinationals to maintain compliance with the "arm's length principle." As corporations often work in several tax jurisdictions simultaneously maintaining an acceptable format helps ensure they adhere strictly to every country's policy where revenue is generated. The OECD guidelines encompass various reputable transfer pricing approaches while defining both arm’s-length principles/standards; also highlighting potential consequences when companies fail to comply effectively with these procedures or expectations. Advanced Pricing and Mutual Agreement Program
HP CASE STUDY Global establishments or entities have the option to engage in this procedure for resolving transfer pricing disputes, whether anticipated or ongoing, as an alternative to evaluation. The Functional Cost Diagnostic Model (FCD) necessitates providing precise financial data and serves as a fiscal tool that arranges and aggregates costs incurred by each involved entity involved in a transfer pricing transaction per EY.com (N.D.). 1. Takeda Pharmaceutical 2. Toys R Us 3. GlaxoSmithKline The focus of this audit is on Hewlett Packard's (HP) human resource management practices, which aim to evaluate and improve the various processes employed by their HR department. According to Bratton and Gold (2017), human resource administration includes hiring and retaining talented employees who can help achieve a company’s goals through recruitment, selection, training, orientation, and promotion procedures. Being a multinational conglomerate in the technology sector with many operating departments worldwide that engage thousands of workers HP must prioritize compliance with standard Human Resource Management principles for optimal efficiency towards attaining strategic objectives such as market share growth, revenue incrementations innovation milestones landmarks thus ensuring long lasting commercial viability. The products range from computer parts like printers, CPU’S Monitors among others reaching diverse consumers requires proper organizational structure enabled by knowledgeable workforce guided regularly evaluated adoption trends emerging technologies need observing legislation adherence diversity inclusion fostering working conditions supporting individual employee self-actualizations amongst other aspects deemed ideal within organizational behavior best accepted approaches situation dependent dynamics.
HP CASE STUDY Objectives The aim of conducting an audit on HP's human resource management process is to enhance understanding of the company's adherence to HR procedures and practices, both at an organizational and professional level. Particularly for Iso accredited enterprises, it is crucial that their HR exemplify strong conformity with diverse placement protocols to encourage attainment of corporate goals and objectives. The audit will thus scrutinize HP's recruitment policies along with hiring techniques, training programs for employees as well as methods used in boarding new personnel - including orientation processes within the firm. Control Tests Audits require control tests to evaluate the effectiveness of a client's measures in preventing errors and addressing issues with their processes. These tests involve reperformance, observations or inspections by an auditor. To conduct HP's HR audit, an inspection control test will be employed to verify if all necessary documentation is complete and compliant with company procedures. The test also aims to ensure that employee salaries are within the recommended range as per salary structures while ensuring essential stamps on filed documents have been provided accurately. Substantive Tests The auditor uses substantive tests to provide evidence and support for control test findings. For HP's HR procedures audit, a designated person will participate in the entire human resource process of the company through observation. This includes being present during interviews and conducting phone interviews with shortlisted candidates to assess whether standardized procedures were followed by HR. The employed substantive test aims at observing how qualified employees are hired while evaluating if resumes meet corporate standards for
Your preview ends here
Eager to read complete document? Join bartleby learn and gain access to the full version
  • Access to all documents
  • Unlimited textbook solutions
  • 24/7 expert homework help
HP CASE STUDY different positions as well. These measures ensure compliance with SHRM guidelines and adherence to all HR processes specified within them. Documentation Intensive documentation of various forms and procedures is required by HR to ensure that a candidate selected for a position has the necessary qualifications and experience compared to other candidates. This process enhances compliance with HR procedures, demonstrating departmental efficiency in hiring highly skilled employees who can aid in achieving corporate objectives. When conducting an audit on human resource management processes, documentation will be critical as it verifies adherence to procedural requirements. The audit will evaluate if employee files contain offer letters outlining job descriptions along with work specifications or employment agreements/contracts conforming standard procedures. Additionally, signed staff reference check guides from referees at previous workplaces are expected too. Sampling Procedures To select a representative section from an entire population, sampling is considered a crucial technique. Furnham and Gunter (2015) define auditing's use of sampling as the process by which auditors take a set number of observations from within said population. Depending on their particular methodology, different forms can be utilized in audit samples like random or purposive ones among others. For this HR audit case study specifically regarding HP records management, simple random sampling will be employed when picking files for evaluation purposes; helping validate data completeness while concurrently ensuring compliance with relevant subjects at hand through these selected documents analyzed against broader trends seen company-wide over timeframes studied here during testing periods conducted internally throughout operations years after completing all steps needed throughout planning beforehand
HP CASE STUDY leading up until execution itself carried out successfully without issue according into best standards practices under appropriate legal guidelines necessary buy each piloting program underway already where possible given current laws ratified recently earlier such great progress been made thanks improvements now being done everywhere around us today! Conclusion Considering all this, HP's success as the world's second largest information and technology firm can be attributed to its skilled management team and well-coordinated workforce. The strategic decisions made by the management keep HP competitive in an ever- changing market. Furthermore, the research & development department advises them on product offerings based on customer needs while working closely with sales & customer service teams to incorporate their feedback for better outcomes.
HP CASE STUDY References Bragg, S. (2023, August 3). Solvency ratios. Accounting Tools. https://www.accountingtools.com/articles/what-are-solvency-ratios.html Hayes, A. (2023, May 23). Profitability ratios: What they are, common types, and how businesses use them. Investopedia. https://www.investopedia.com/terms/p/profitabilityratios.asp Laptop computers, desktops, printers, ink & toner. Laptop Computers, Desktops, Printers, Ink & Toner. (n.d.). https://www.hp.com/us-en/home.html Liquidity ratio. Corporate Finance Institute. (2023, October 4). https://corporatefinanceinstitute.com/resources/accounting/liquidity-ratio/ Hayes, A. (2023). Profitability Ratios: What They Are, Common Types, and How Businesses Use Them. Investopedia. https://www.investopedia.com/terms/p/profitabilityratios.asp Hayes, A. (2023, March 19). Understanding Liquidity Ratios: Types and Their Importance. Investopedia. https://www.investopedia.com/terms/l/liquidityratios.asp Hayes, A. (2022, June 28). How to Use the Solvency Ratio. Investopedia. https://www.investopedia.com/terms/s/solvencyratio.asp Laptop Computers, Desktops, Printers, Ink & Toner. (n.d.). Www.hp.com. http://www.hp.com/ OECD / G20, 2015, Transfer Pricing Documentation and Country-by-Country reporting, Action 13 – 2015 Final Report
Your preview ends here
Eager to read complete document? Join bartleby learn and gain access to the full version
  • Access to all documents
  • Unlimited textbook solutions
  • 24/7 expert homework help
HP CASE STUDY https://read.oecd-ilibrary.org/taxation/transfer-pricing-documentation-andcountry-by- country-reporting-action-13-2015-final-report_9789264241480-en#page2 Klaarman, Krisli, N.D. Intragroup services caught the attention of the tax authorities. https://www2.deloitte.com/content/dam/Deloitte/ee/Documents/aboutdeloitte/Krisli %20Klaarman%20%20Intragroup%20services%20caught%20the%20attention%20of %20tax%20authority.pdf Tax Justice Network, N.D. Transfer Pricing https://www.taxjustice.net/topics/corporate-tax/transfer-pricing/ Piascik.com, N.D. IRC Section 482 https://www.piascik.com/client-resources/information-center/allocation-incomeand- deductions IRS.gov, LB&I International Practice Service Transaction Unit https://www.irs.gov/pub/int_practice_units/ISI9422_09_02.pdf Chen, Kelly, N.D. Overview of US Transfer Pricing Issues and New Cost Sharing Regulations Issued by the IRS http://files.ali-cle.org/thumbs/datastorage/lacidoirep/articles/PTXL0908-Chen_thumb.pdf Royalty Rage, January 2019, Comparable Uncontrolled Price (CUP) Method https://www.royaltyrange.com/home/blog/transfer-pricing-comparableuncontrolled-price- cup-method Valentiam.com, February 14, 2019, The Resale Price Method in Transfer Pricing Explained https://www.valentiam.com/newsandinsights/resale-price-method Peavler, Rosemary, May 31, 2019, Defining and Calculating Cost-Plus Pricing https://www.thebalancesmb.com/cost-plus-pricing-393274
HP CASE STUDY Royalty Rage, December 2017, Transfer Pricing Methods https://www.royaltyrange.com/home/blog/transfer-pricing-methods OECD.org, 2017, OECD Transfer Pricing Guidelines for Multinational enterprises and tax administration https://read.oecd-ilibrary.org/taxation/oecd-transfer-pricing-guidelines- formultinationalenterprises-and-tax-administrations-2017-tpg-2017-en#page1 EY.com, February 2019, US advanced pricing and mutual agreement program releases functional cost diagnostic model to be used in certain APAs. https://taxinsights.ey.com/archive/archive-news/us-advance-pricing-and- mutualagreement-program.aspx Bratton, J., & Gold, J. (2017). Human resource management: theory and practice. Palgrave. Furnham, A., & Gunter, B. (2015). Corporate assessment (Routledge Revivals): auditing a company's personality. Routledge. Knechel, W. R., & Salterio, S. E. (2016). Auditing: Assurance and risk. Taylor & Francis.