Information technology,organizational design,and transfer pricing

We show how information technology affects transfer pricing. With coarse information technology, negotiated transfer pricing has an informational advantage: managers agree to prices that approximate the firm's cost of internal trade more precisely than cost-based transfer prices. With sufficiently rapid offers, this advantage outweighs opportunity costs of managers’ bargaining time, and negotiated transfer pricing generates higher profits than the cost-based method. However, as information technology improves, the informational advantage diminishes; the opportunity costs of managers’ bargaining eventually dominate, and cost-based methods generate higher profits. Our results explain why firms generally prefer cost-based methods, and when negotiated methods are preferable.     

Cost-based transfer pricing

This paper compares the performance of alternative cost-based transfer pricing methods. We adopt an incomplete contracting framework with asymmetric information at the trading stage. Transfer pricing guides intra-company trade and provides incentives for value-enhancing specific investments. We compare actual-cost transfer prices that include a markup over marginal costs with standard-cost transfer prices that are determined either by the central office ex ante (centralized standard-cost transfer pricing) or by the supplying division at the trading stage (reported standard-cost transfer pricing). For the actual-cost methods, we show that markups based on the joint contribution margin (contribution-margin transfer pricing) dominate purely additive markups (cost-plus transfer pricing). We obtain the following results. (1) Centralized standard-cost transfer pricing dominates the other methods if the central office and the divisions ex ante face low cost uncertainty. (2) The actual-cost methods dominate the other methods if the central office and the divisions ex ante face high cost uncertainty and later, at the trading stage, the buying division receives sufficient cost information. (3) Reported standard-cost transfer pricing dominates the other methods if the central office and the divisions ex ante face high cost uncertainty, and the buyer has insufficient cost information at the trading stage.     

Strategic choices of quality,differentiation and pricing in financial services

Two financial services firms (FSFs) produce information on future returns from risky assets, incorporate this information in a report and sell the reports to investors. The FSFs make strategic choices of the quality, differentiation and prices of their reports. Their optimal strategic choices of quality and differentiation divide the market for the report into three segments. Each FSF has a monopoly in its own segment, and the two compete head-to-head in a duopoly segment. The sizes of the monopoly segments increase with increases in quality and differentiation. An increase in differentiation reduces the size of the duopoly market, while an increase in quality has an ambiguous effect on the duopoly market: for high enough equilibrium differentiation, the size of the duopoly market decreases with an increase in quality. The non-cooperative FSFs pursue niche strategies, each focusing on a different related set of risks, in order to coordinate the contents of their reports to achieve the equilibrium degree of product differentiation. Recent years have seen a worldwide wave of financial-firm mergers and acquisitions. This paper’s model suggests that in equilibrium FSFs differentiate their products and develop profitable niches; in principle, however, sufficiently strong economies of scope could lead to a small number of FSFs with little differentiation that dominate all financial services markets.     

A graphical analysis of profit variances under absorption and direct costing

This note describes a graphical approach that illustrates how the different treatment of fixed manufacturing overhead affects absorption and direct costing profit variances when actual sales and production volumes deviate from the planned ones.     

Organizational views of transfer pricing

Models of organization provide different sets of conceptual lenses for describing a transfer pricing decision context. Each model provides different explanations or views of events. Implications of these models or views for framing this decision context as well as for the dimensions and process of choice are discussed.     

A model of cost-based transfer pricing

In most decentralized organizations, goods and services are transferred between divisions. These transfers are frequently recorded in the accounting books of the divisions; the term transfer price refers to the dollar amount of the interdivisional exchange. This study considers two main issues: (i) the costs and the benefits of delegating decisions through a system of transfer pricing and divisional performance evaluation, and (ii) the performance of one common method of pricing intrafirm transactions: cost-based transfer pricing.The study analyzes a firm in which each divisional manager has better information about the divisional environment than what is known by the firm's top management. The first half of the paper demonstrates that the firm can attain the optimal level of profits with a compensation system utilizing (i) reports by divisional managers describing in complete detail each manager's private information, and (ii) divisional performance evaluation with cost-based transfer pricing. Next, a situation is considered in which divisional managers are not able to communicate their private information to the firm's top management because of complexity of divisional environments or managers' specialized expertise. In this bounded-rationality setting, a managerial-compensation system employing cost-based transfer pricing allows the firm to earn strictly higher expected profits than if all decisions are made by the firm's top management relying on divisional managers' reports.Financial support from the Unisys Corporation is gratefully acknowledged.     

Dual transfer pricing with internal and external trade

This paper examines a transfer pricing problem between two divisions of a decentralized firm. The selling division is privately informed about its own costs and produces a good that is sold both externally in an intermediate market and internally within the firm. Unlike most previous work, we focus on dual transfer pricing systems that allow the selling division to be credited for an amount that differs from the amount charged to the buying division. We identify conditions under which efficient decentralized trade and external price setting incentives can be provided with a properly chosen set of dual transfer prices that do not rely on direct communication. Instead, the optimal dual transfer prices will depend only on public information about the market price charged by the upstream division in the external market, which indirectly communicates information about production costs to the downstream division. For a variety of well-known demand functions, the optimal transfer prices will be linear functions of the market price. Our main results hold when the upstream division faces multiple internal buyers or faces a binding capacity constraint.     

Divisional performance measurement and transfer pricing for intangible assets

This paper examines the effectiveness of three transfer pricing methodologies for an intangible asset that is developed through bilateral, sequential investment. In general, a royalty-based transfer price that can be renegotiated provides better investment incentives than either a non-negotiable royalty-based transfer price or a purely negotiated transfer price, and in some cases induces first-best investment. This result contrasts with previous research that finds that the inability to limit renegotiation of initial contracts reduces investment efficiency. Further, I examine how tax transfer pricing rules inform optimal internal transfer prices when the firm decouples internal and external transfer prices.     

The teaching of transfer pricing: Theory and examples

This paper presents a unified framework for teaching transfer pricing at the advanced undergraduate or Masters levels. The approach is based on the economic transfer pricing model of Hirshleifer [Hirshleifer, J. (1956). On the economics of transfer pricing. Journal of Business, 29 (July), 172–184; Hirshleifer, J. (1957). On the economics of the divisionalized firm. Journal of Business, 29 (April), 96–108] but uses a series of numerical examples to “flesh out” the principles arising from the purely diagrammatic approach taken by Hirshleifer. We also develop numerical examples that illustrate the effects that removing the frictionless markets assumptions (that underscore the Hirshleifer approach) can have on optimal transfer pricing rules. The focus here is on the lack of goal congruence introduced by agency considerations and the role of accounting procedures in alleviating these agency issues. The teaching materials embodied in this article were developed “at the coalface” and have been successfully used by the authors in advanced undergraduate managerial accounting classes.     

An outcome-based assessment of international transfer pricing policy

Instead of concentrating on the selection of the optimal transfer pricing method, this paper focuses on the consequences of international transfer pricing for multinational entities. A sample of U.S.-based multinational firms is employed to determine if transfer pricing results in measurable financial outcomes. Results of the study indicate that firms employ international transfer pricing to meet a variety of objectives. The dollar value of international transfers and the foreign sales percentage are both significant explanatory variables for the financial outcomes of these objectives.     

Strategic pricing by Big 4 audit firms in private client segments

We examine how Big 4 auditors compete for new private clients. We find evidence suggesting that Big 4 auditors offer fee discounts to attract non‐Big 4 private clients to experience attributes of their brand name audit services. We also find that to attract clients from competing Big 4 suppliers, Big 4 auditors target fee discounts at clients in industries where they are the market leader. Our results further indicate that the Big 4 industry leaders target fee discounts to fast‐growing clients and are able to charge these clients significant price fee increases in the second mandate period (after 3 years).     

Towards an organizational theory of the transfer pricing process

Understanding the transfer pricing issue as it arises in large decentralized firms is important, because it represents a pervasive problem in the design of managerial accounting and control systems in complex organizations. This paper draws on the growing literature on the economics of internal organization to develop an understanding of the strategic, organizational and transactional conditions under which transfer pricing (and related control) issues arise, and the organizational processes used to implement intra-firm transfers of products and to determine transfer prices. The objective of the paper is to develop a theory of the transfer pricing process and to reduce hypotheses from the theory.     

Transferring priorities: a three-act play on transfer pricing

We present the discourse which surrounds the implementation of a transfer pricing system for a major company in the financial services sector. This discourse is superficially mundane and yet constitutes a problematic piece of text for which several readings are possible. Rather than close down interpretation by imposing a single reading, we develop a critique which juxtaposes critical perspectives and references to the text. The paper illustrates the many ways in which critical perspectives are relevant to an understanding of practice. In broad terms, the power of accounting is illustrated through its agenda-shaping potential, and shaping the agenda is shown to be capable of countering this power. A final section suggests that critical perspectives offer a more enlightened and optimistic programme than does the discourse of transfer pricing, which is to be found in practice.     

A longitudinal study of the determinants of transfer pricing change

Evidence of a change in transfer price offers a rare opportunity to examine underlying causes to explain the need for change. Three modern-day frameworks are employed in this longitudinal case study to interrogate the events and actions taken at an iron and coal company during the last quarter of the 19th century. This approach provides insights to potentially influential factors effecting transfer price determination which may be neglected or overlooked in current theoretical or empirical studies.     

Goliath Corporation: An instructional case in transfer pricing policy

This case illustrates some of the issues associated with setting firms’ transfer pricing policies. The simulation requires students to assume the roles of top management and divisional management for Goliath Corporation in negotiating transfer prices. The student playing the role of top management first selects a transfer pricing policy from four possible mechanisms: market-based, cost-based, negotiated, and dual-pricing. Given the top manager’s policy choice, divisional managers are then constrained to use that policy as they decide whether to purchase internally or externally based on their respective negotiations. In each negotiation, there is an ex ante best decision for Goliath as a whole. The case is thus useful in demonstrating how managers’ transfer price policy choices can lead to bad sourcing decisions.     

Management control in the transfer pricing tax compliant multinational enterprise

This paper studies the impact of transfer pricing tax compliance on management control system (MCS) design and use within one multinational enterprise (MNE) which employed the same transfer prices for tax compliance and internal management purposes. Our analysis shows immediate effects of tax compliance on the design of organising controls with subsequent effects on planning, evaluating and rewarding controls which reveal a more coercive use of the MCS overall. We argue that modifications to the MCS cannot be understood without an appreciation of the MNEs’ fiscal transfer pricing compliance process.     

Challenging the reliability of comparables under profit-based transfer pricing methods

Under profit-based transfer pricing methods, the selection of comparable companies is essential if detection of transfer price manipulation is to be reliable. Comparative advantage as embedded in internalisation theory argues that foreign-controlled companies (FCCs) should, in the long run, display greater profitability than domestic-controlled companies. In high-tax host countries, transfer pricing manipulation theory predicts an opposite effect on profitability. Applying a refined set of tests to a large sample of firms operating in a high-tax country such as Italy offers strong support for the internalisation prediction. Furthermore, the analysis of the interquartile range of our measure of profitability indicates that only a low percentage of FCCs would be subject to fiscal enquires, as implied by the Organisation for Economic Co-operation and Development guidelines, under the suspicious of transfer pricing manipulation. These results suggest that current comparability tests are likely to fail the identification of transfer pricing practices in countries where the comparative advantage of FCCs is particularly pronounced and question the reliability of these tests.     

An empirical study of voluntary transfer pricing disclosures in China

This paper empirically investigates the factors that affect the management’s voluntary disclosures of the transfer pricing details of related-party transactions. Using Chinese data from 2004 and 2005, we hypothesize and find that firms that make voluntary disclosures of the pricing methods of related-party transactions are negatively associated with (i) a higher level of earnings management (as captured by abnormal related-party transactions) and (ii) its underlying incentives (as captured by the management’s performance-linked bonuses and the firm’s incentives to achieve earnings targets); further, they are positively associated with (i) a higher percentage of independent directors and (ii) a higher percentage of government ownership. Overall, our findings suggest that earnings management and its incentives, board composition, and ownership structure significantly influence the voluntary disclosure decisions of managers.