The Fuqua School of Business Duke University

International Strategy: WBA 434 Professors Heath, Huddart, & Slotta

Transfer Pricing 1. Overview

An essential feature of decentralized rms is responsibility centers (e.g., cost-, prot-, revenue-, or investment-centers). The performance of these responsibility centers is evaluated on the basis of various accounting numbers, such as standard cost, divisional prot, or return on investment (as well as on the basis of other non-accounting measures, like market share). One function of the management accounting system therefore is to attach a dollar gure to transactions between dierent responsibility centers. The transfer price is the price that one division of a company charges another division of the same company for a product transferred between the two divisions. The basic purpose of transfer pricing is to induce optimal decision making in a decentralized organization (i.e., in most cases, to maximize the prot of the organization as a whole). Prot Center : Any sub-unit of an organization that is assigned both revenues and expenses. In a prot center, a manager is treated as an entrepreneur. Typically, a prot center manager is given decision-making power and is held responsible for the prots generated by her center.

2.
2.1

Advantages and Disadvantages of Decentralization

Decisions are better and more timely because of the managers proximity to local conditions. Top managers are not distracted by routine, local decision problems. Managers motivation increases because they have more control over results.
Based on a note by Nahum Melumad.

c Heath, Huddart & Slotta, 2009. All rights reserved.

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WBA 434: International Strategy

Transfer Pricing

Increased decision making provides better training for managers for higher level positions in the future. 2.2 Disadvantages

Lack of goal congruence among managers in dierent parts of the organization. Insucient information available to top management; increased costs of obtaining detailed information. Lack of coordination among managers in dierent parts of the organization.

3.

Purposes of Transfer Pricing

Generate separate prot gures for each division and thereby evaluate the performance of each division separately. Help coordinate production, sales and pricing decisions of the dierent divisions (via an appropriate choice of transfer prices). Transfer prices make managers aware of the value that goods and services have for other segments of the rm. Transfer pricing allows the company to generate prot (or cost) gures for each division separately. The transfer price will aect not only the reported prot of each center, but will also aect the allocation of an organizations resources.

4.

Mechanics of Transfer Pricing

No money need change hands between the two divisions. The transfer price might only be used for internal record keeping. (Transfer Price quantity of goods exchanged) is an expense for the purchasing center and a revenue for the selling center.
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5.

Accounting for Transfer Pricing

If intra-company transactions are accounted for at prices in excess of cost, appropriate elimination entries should be made for external reporting purposes. Examples of items to be eliminated for consolidated nancial statements include: Intracompany receivables and payables. Intracompany sales and costs of goods sold. Intracompany prots in inventories.

6.

Alternative Methods of Transfer Pricing

A transfer pricing policy denes rules for calculating the transfer price. In addition, a transfer price policy has to specify sourcing rules (i.e., either mandate internal transactions or allow divisions discretion in choosing whether to buy/sell externally). The most common transfer pricing methods are described below. 6.1 Market-based Transfer Pricing

When the outside market for the good is well-dened, competitive, and stable, rms often use the market price as an upper bound for the transfer price. Concerns with market-based Transfer Pricing When the outside market is neither competitive nor stable, internal decision making may be distorted by reliance on market-based transfer prices if competitors are selling at distress prices or are engaged in any of a variety of special pricing strategies (e.g., price discrimination, product tie-ins, or entry deterrence). Also, reliance on market prices makes it dicult to protect infant segments. 6.2 Negotiated Transfer Pricing

Here, the rm does not specify rules for the determination of transfer prices. Divisional managers are encouraged to negotiate a mutually agreeable transfer price. Negotiated transfer pricing is typically combined with free sourcing. In some companies, though, headquarters reserves the right to mediate the negotiation process and impose an arbitrated solution.
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6.3

Cost-based Transfer Pricing

In the absence of an established market price many companies base the transfer price on the production cost of the supplying division. The most common methods are: Full Cost

Cost-plus

Variable Cost plus Lump Sum charge Variable Cost plus Opportunity cost Each of these methods is outlined below. 6.3.1 Full Cost Dual Transfer Prices

A popular transfer price because of its clarity and convenience and because it is often viewed as a satisfactory approximation of outside market prices. (i) Full actual costs can include ineciencies; thus its usage for transfer pricing often fails to provide an incentive to control such ineciencies. (ii) Use of full standard costs may minimize the ineciencies mentioned above. 6.3.2 Cost-plus

When transfers are made at full cost, the buying division takes all the gains from trade while the supplying division receives none. To overcome this problem the supplying division is frequently allowed to add a mark-up in order to make a reasonable prot. The transfer price may then be viewed as an approximate market price. 6.3.3 Variable Cost plus a Lump Sum Charge

In order to motivate the buying division to make appropriate purchasing decisions, the transfer price could be set equal to (standard) variable cost plus a lump-sum periodical charge covering the supplying divisions related xed costs.
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6.3.4

Variable Cost plus Opportunity Cost

Also know as the Minimum Transfer Price:

Minimum Transfer Price = Incremental Cost + Opportunity Cost.

For internal decision making purposes, a transfer price should be at least as large as the sum of: cash outows that are directly associated with the production of the transferred goods; and, the contribution margin foregone by the rm as a whole if the goods are transferred internally. Sub-optimal decisions can result from the natural inclination of the manager of an autonomous buying division to view a mix of variable and xed costs of a selling division plus, possibly, a mark-up as variable costs of his buying division. Dual transfer pricing can address this problem, although it introduces the complexity of using dierent prices for dierent managers.

6.3.5

Dual Transfer Prices

To avoid some of the problems associated with the above schemes, some companies adopt a dual transfer pricing system. For example: Charge the buyer for the variable cost. The objective is to motivate the manager of the buying division to make optimal (short-term) decisions. Credit the seller at a price that allows for a normal prot margin. This facilitates a fair evaluation of the selling divisions performance.
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7.

Example of Conicting Incentives and Transfer Pricing

FC $31,000 VC $120/unit

Transfer Price

B
Sales P = $300/unit

Sales P = $200/unit
FC: Fixed costs VC: Variable costs

FC $5,000 VC $150/unit

Suppose all markets are perfectly competitive and that managers are motivated to maximize short-run prot. The production capacity (as well as standard) of department A is 1,000 units. Denote the quantity transferred by x. Consider two alternative scenarios: Centralized decision maker who maximizes overall rms prots: Maximize (PA VA )(1,000 x) + (PB VB VA )x =(200 120)(1,000 x) + (300 150 120)x

=80,000 50x

Two decentralized decision makers, each maximizing her divisions prots: Prot A = (200 120)(1,000 x) + (T P 120)x = 80,000 + (T P 200)x Prot B = (300 150 T P )x = (150 T P )x
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(1) What price would induce both managers to choose x = 0? Answer: (2) What is the minimum transfer price according to the course text? Answer: Variable cost + Opportunity cost =120 + 80 =200 (3) What is the transfer price according to the variable cost and full cost methods? Answer: Variable cost: 120 Full cost: 120 + 31,000/1,000 = 151 (4) When is the variable cost-based transfer price appropriate? Answer: When the opportunity cost is zero and Division A is evaluated as a cost center. (5) Suppose, in the example above, that we do not have a perfect market. Division A can sell up to 800 units at $200 but no more. What would happen under each of the transfer price schemes discussed above? Answer: With the Division A manager free to sell his product to the highest paying buyer and a transfer price of 120 T P 150, the rst 800 units will be sold to the outsider and the remainder will be sold to Division B. 150 T P 200

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Transfer Pricing

8.

Taxes, Prot Repatriation, and Transfer Prices

The next two examples describe additional exogenous factors aecting the choice of a transfer pricing scheme. 8.1 Example: Tax implication of transfers across countries A and B are divisions of the ABC company. The A division is located in Silicon where the marginal tax rate is 50%. The B division is located in Sand where the marginal tax rate is 30%. The A division produces an intermediate product at a cost of $100 per unit and then transfers this product to the B division where it is nished at an additional cost of $100 and sold for $500. Assume 1,000 units are transferred annually and that the minimum transfer price allowed by the Siliconi IRS is the variable cost. (1) What transfer price should be charged in order to minimize taxes? Answer: $100. 8.2 Example: Transferring funds out of a foreign country Continue the previous example. The Sandi government does not allow corporations investing there to transfer earnings out of the country. Suppose the parent company wants to use some of its consolidated earnings (including the earnings of the B division) to either pay dividends or invest in a new project outside of Sand. One option for removing capital from Sand is through the use of a high transfer price. In this case the B division would actually pay the A division the amount of the transfer price, which would result in earnings of the consolidated entity appearing as the income of the A division rather than the B division. This may be desirable since the parent company controls earnings of the A division but not of the B division. The Sandi IRS restricts the transfer price to being no less than the variable cost. (2) What transfer price should division A charge to exercise control over all prots? Answer: $400. (3) What is the cost associated with this transfer pricing scheme choice? Answer: There is an adverse tax eect. Relative to the example above, the ABC Company loses (400 100)(50% 30%) 1,000 = $60,000
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The essence of decentralization lies in the freedom of middle and lower managers to make decisions. The decentralization of an organization is a matter of degree.

9.

Observations
In most organizations:

Obtaining specialized (or local) information is costly. Communication of information is costly. There exist interdependencies between the decisions of dierent managers in terms of the outcome to the rm as a whole. Transfer pricing is often complicated by imperfect, ill-structured, or nonexistent intermediate markets. Imperfect competition occurs when a single buyer or seller can inuence the market price. If imperfect competition exists in the intermediate market, additional volume can be obtained if selling prices are lowered, thus causing transfer-price analyses to be exceedingly complex. In such a case, an optimal transfer pricing scheme may be volume dependent. An economic analysis might dictate that variable cost be used as the transfer price, but this would seldom be appropriate for dealing with other aspects of the managerial problems that present themselves simultaneously: achieving goal congruence, motivating managerial eort, and making good use of local information in a decentralized organization. Therefore, dierent kinds of transfer prices (for example, market prices and cost-based transfer prices) may be assigned. A primary reason for decentralizing the decision making in an organization is the existence of information asymmetry. Textbook examples often imply that there is some individual in the organization with all of the necessary information (incremental costs, opportunity costs, revenues, etc.) for all of the organizations divisions. Yet, if this were the case we would not have needed a decentralized organization in the rst place. If a perfectly competitive market existed for the intermediate good transferred between two divisions, then from an economic perspective, nothing would be lost by severing the rm at that point. The amount of information to be managed is extremely large.

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