Transfer pricing at heart of Pfizer case
Shareholders allege that Pfizer has deliberately contributed to poor results at its Pakistan operations, thus diluting the value of the minority stakeholders’ shares
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Pfizer in Pakistan
As a businessman I am unable to fathom the business strategy of Pfizer’s operations in Pakistan. The facts as reported in the Judgment are: a)Pfizer Laboratories Ltd. has accumulated losses of Rs 930.3 million till 2002; b) its two main products are being sold at gross loss – which means that increase in sales would result in greater losses; c) the company is presumably paying taxes thereby increasing these losses further – I know that Tax authorities have their own system of assessing ‘true’ profits and take a careful look at inter-company transactions disallowing what they deem to be any excess loading; and finally d) the parent company is financing these losses by injecting equity capital which would clearly be classified as ‘dead’ investment at their end and would have to be written off as ‘bad’ investment in due course. But as the parent company is selling the raw materials: in case of Amlodepine Besylate at 60 times [US$ 30,000 per kg vs. US$ 500 per kg] and Piroxicam at 70 times [US$ 8,750 vs. US$ 125 per kg] their respective market prices –these numbers are just incredible- the parent company or the affiliated company must be earning and showing very good margins in their own books.
So, the question is that does the write-off of their investment balances the net earnings from sale of raw materials? Forgetting the plight of minority shareholders for a minute, one supposes that must be so for all this to make any sense. But then earnings are a profit and loss [‘above the line’] item whereas write-off is a ‘below the line’ item – which in lay terms means ‘window dressing’ as current earnings get inflated to be reduced subsequently when investments are written off.. This sounds sinister as this was precisely what Enron – the largest collapse in US corporate history- was accused of doing. As a shareholder in Pfizer U.S. I am alarmed that the parent company is condoning such actions and perhaps Securities & Exchange Authority needs to b
Mumtaz