« The price of transfer enters the companies
belonging to a group of multinational corporations was one of the subjects of
exposed on the tax, during several years, particularly in the United States of
America. Nevertheless, considerable factors which have occurred in the interval
of the years '80 and '90 made that this subject became one of most interesting
and of most sensitive to all the companies. » (Chris Rolfe, 1993, V).
Problem thorny in the various international forms of cooperation, as regards
investments, certainly, the concept of price of transfer, known as professor
Van Den Bulcke, returns resolutely to the concept of trade intra-group. This
one, writes it, «consists in the international transactions (exports and
imports) inside the multinational corporations (EM), i.e., of the companies
which are located in at least two countries.
(Van Den Bulcke Daniel, 1982, p. 171). We could not have
access to the statistical data which would have made it possible to measure the
flow of these commercial transactions between the various members of the Ajax
group, for example. But, nothing offers really the avoidance of such a
problem.
In the group Paris Saint-Germain, it was a question of
recruiting the young African players, to select most powerful by making them
involve in the Tunisian club of Hope of Tunis. This stage, the second of a long
process, more deserving would have gone to Switzerland to the club Servette
from which two or three the best would leave, to go to join the mother team,
it, refuge of rare pearls. According to the Special report of the emission
Correspondent of Tuesday October 17, 2000 out of France 2, Paris Saint-Germain,
after having joined deprived in the center of formation of Burkina, just before
it is not withdrawn, would have actually recruited some defectors of the center
Planet. On such an assumption, the local partners could be opposed to the
purchase by the Parisian club of a player to an allowance which would not
reflect real balance between supply and demand, because, as recognizes it
professor Van Den Bulcke « it is very doubtful that the prices
recorded for these transactions reflect simply supply and in a competitive
market » (Ibidem). In the same way, the Last above mentioned
Hour paid on the same columns as the young players coming from South Africa and
of Ghana, where Ajax of Amsterdam had consolidated his presence, were to
involve itself with the GBA, before joining Amsterdam. It is specified thus
that, in the case of the partnership between clubs firms and clubs local
partners, several scenarios can think, but especially as regards transfer of
the young players.
Example : Ajax Cape Town, partner local of Ajax of
Amsterdam, trains a player of particularly gifted football. Whereas the player
is at the top of his talent, Ajax of Amsterdam requests his transfer in the
mother team, by proposing in Ajax Cape Town an allowance that this last
estimates not to correspond to the real allowance if the same transfer should
be requested by a team of football not belonging to the Ajax group.
Much more, there is not only the local club which could
complain about handling of the prices of transfers. The State of the country of
the local club him also could be seen opposing a clever refusal to levy
taxation of the incomes acquired with the club under rights of retransmission
of the matches, merchandizing, sponsoring.
On the assumption of a control of the management of the local
club by a personnel expatriate, completely dedicated to the defense of the
interests of the club firm, this last can dissimulate the exact value of the
incomes of the club and thus succeed in making them escape the tax department
country from the partner team.
How could one solve such a conflict all while maintaining the
investment ?
Before answering this question, one can put the question to
know if the transfer of the players can cause the debate on the price of
transfer. Coopers and Lybrand (1993, p. 4) retort that « there
are several types of transactions intra-group. They include the transfers of
the tangible and intangible goods, of provisions of services and finances, but
also the agreements of leasing. ». « The important thing,
insist, it is to note that it is the substance which will always so yes
determine or not the transaction took place. » Thus, even if the
player, as a man, must be regarded as extra-commercium, its transfer showed
lately that it was indeed about a commercial deal, that the clubs belonging to
the same group could also practice.
