Dynamic transfer pricing under conditions of uncertainty – the use of real options

2019 ◽  
Vol 15 (4) ◽  
pp. 535-556 ◽  
Author(s):  
Jan M. Smolarski ◽  
Neil Wilner ◽  
Jose G. Vega

Purpose This paper aims to examine the applicability of real options methodology with respect to developing internal transfer pricing mechanisms. A pervasive theme in existing models is their inability to handle the dynamic and volatile nature of today’s business environment, as well as their lack of objective managerial flexibility. The authors address these and other issues and develop a transfer pricing mechanism based on Black–Scholes and the binomial options pricing methodology, which is better suited in today’s dynamic business environment. Design/methodology/approach The authors use a conceptual approach in developing theoretical justifications and show, practically, how a transfer price can be developed using two different real options pricing models. Findings The authors find that real options transfer price mechanism (real options framework [ROF]) can effectively deal with many of the issues that permeate a modern organization with complex multi-dimensional operations. The authors argue that uncertainty and behavioral issues commonly associated with setting transfer prices are better handled using a transfer pricing mechanism that preserves flexibility at the business unit level, the managerial level and the firm level. The approach allows for different managerial styles in both centralized and decentralized sub-units within the same organization. The authors argue that an open multi-dimensional framework using real options is suitable under conditions of uncertainty and managerial opportunism. Practical implications ROF-based transfer pricing may be significant in that firms can use it as a tool to manage an organization by setting the prices centrally and at the same time allowing managers to select the transfer price that best suits their specific situation and operating conditions. This may result in a more efficient and more profitable organization. Originality/value The contribution of the paper is the melding of the ROF from the finance literature with the accounting problem of setting a transfer price for items lacking a competitive market price. The authors also contribute to existing research by explicitly developing a framework that values managerial flexibility, takes into account uncertainty and considers the behavioral aspects of the transfer pricing process. The authors establish the conditions under which a generic real options model is a feasible alternative in determining a transfer price.

Author(s):  
Canri Chan

This study investigated the effects of government regulations and incentives on the setting of transfer prices. I found significant main effects of both variables on transfer price choices. Transfer pricing is important, particularly for Multinational Corporations (MNCs), because of increased trends toward globalization of business activities and, simultaneously, decentralization. These trends have led to increased pressures for sound internal pricing systems, specifically transfer pricing, in order for organizations to ensure optimal and efficient allocations of organization resources and to provide profit performance measurements (Tang 1992). It has generally been recognized in the literature that in order to maximize after tax cash flows, MNCs shift profits from high to low tax jurisdictions. Governments in some countries, particularly those with high tax rates, are greatly concerned as to whether or not companies attempt to avoid tax liabilities via transfer pricing manipulation, specifically in terms of trying to shift profits to lower tax jurisdictions, and have enacted laws to limit transfer price choice.


2015 ◽  
Vol 5 (8) ◽  
pp. 1-11
Author(s):  
Mariam Cassim ◽  
Linda Ronnie

Subject area Change Management. Study level/applicability Postgraduate business courses, including MBA courses in change management and human resource management. Case overview This case study emphasises how important it is for organisations operating in today's turbulent and rapidly changing business environment to have an emergent approach to change. It focuses on the dilemmas faced by Hemmanth Singh, the newly appointed Managing Executive responsible for Mobile Commerce at Vodacom South Africa. Singh is responsible for the execution of the new strategy into financial services, the relaunch of M-Pesa into the South African market being the immediate task. The case sets the context for the relaunch of M-Pesa, and the reader is introduced to some of the limitations and challenges experienced by the company when trying to replicate a successful business model from one market to another, especially after an unsuccessful initial launch. Expected learning outcomes After reading and analysing the information contained in the case study and appendices, students should be able to evaluate the critical role that leadership needs to play when introducing and implementing a change initiative at an organisation that is stimulated by evolving external market conditions; understand the importance of adopting an emergent approach to change in current operating conditions; identify the factors that contribute to or hinder the creation and sustainability of an adaptive culture within an organisation; and appreciate the challenges of attempting to replicate a successful business model from one market into another. Supplementary materials Teaching Notes are available for educators only. Please contact your library to gain login details or email [email protected] to request teaching notes.


2021 ◽  
Vol ahead-of-print (ahead-of-print) ◽  
Author(s):  
Jumpei Hamamura

Purpose This study aims to analytically explore the economic role of transfer pricing in a vertically integrated supply chain with a direct channel, specifically when it uses cost-based transfer prices, as is frequently observed in management practices. We compare two representative transfer pricing methods: full-cost and variable-cost pricing. Although many firms open a direct channel, which affects the optimal decision on transfer prices, prior literature has not considered this case. Design/methodology/approach We demonstrate the results using a non-cooperative game theoretical approach. Findings The results show that full-cost pricing is more profitable than variable-cost pricing when the fixed cost allocation to the marketing division is low, contrary to the established position in prior studies, from which I select their benchmark case. Moreover, we obtain a counterintuitive result, whereby, the firm-wide profit of a vertically integrated supply chain increases with fixed cost allocation. Originality/value This study considers the direct channel and internal transfer pricing in a vertically integrated supply chain, while prior research only considers one or the other. This model suggests an optimal choice of cost-based transfer pricing in managerial decisions. In addition, the authors demonstrate the positive effect of increasing fixed cost allocation, which prior management studies do not show. The findings of this study have implications for managerial practice by providing insights into supply chain design and showing that firms should consider the competition between channels when making decisions about transfer pricing methods.


2019 ◽  
Vol 30 (1) ◽  
pp. 115-119
Author(s):  
Diana Petrova

This paper treats the role and significance of international transfer pricing in the activities of modern globally operating companies in the contemporary conditions of constantly increasing globalization of the world economic area. The main goals and tasks pursued by the mechanism of international transfer pricing in the hyper competitive, highly risky and dynamically changing global business environment are explained. The key accounting problems related to the processes of planning, analysis and control of specific strategies of international transfer pricing in the globally oriented companies are discussed. The rapid development of globalization processes in contemporary conditions determines the growth of the significance and application of international transfer pricing in the activities of modern globally operating companies. Increasing the degree of their economic integration and the amount of their intra-corporate exchange, as well as the increasing complexity of their international transactions, make international transfer pricing one of the most important and topical problem that is faced by these companies.The main goal pursued by the mechanism of international transfer pricing is to optimize activities and maximize overall profits for the company as a whole on a global basis. The accounting problems that may arise in connection with international transfer pricing in modern globally operating companies are in two main aspects:  problems in terms of information provision of the internal management processes that occur in the different subsidiaries and within the company as a whole;  problems in providing the necessary accounting information for the purpose of compiling the financial statements and satisfying the information needs of the interested external users. The accounting information system of globally operating companies should be able to meet the information needs of their distinctive uniform system of making decisions aimed at coordinating goals on a global basis, successfully implementing the global strategy and optimizing resources and results globally. The accounting must provide adequate information needed to make sound management decisions concerning the policy of international transfer pricing that is implemented, to control the implementation of these decisions and subsequently to assess and analyze the results. A key problem for globally operating companies is implementing such a policy of international transfer pricing that ensures optimal results for the company as a whole and at the same time successful practical implementation of the requirement for consistency of the goals of all units operating within the overall organizational structure. Considerable difficulties arise in the objective assessment of costs and benefits of the application of transfer prices in the implementation of numerous and diverse international operations between the different constituent structural units of the company and the making of sound management decisions based on this.


2019 ◽  
Vol 3 (1) ◽  
Author(s):  
Novi Swandari Budiarso ◽  
Winston Pontoh

Determination of transfer prices and selling prices is not only a matter of large companies. This problem can occur in a type of Small and medium enterprise. But sometimes managers from small and medium businesses do not realize that in their business there is a transfer price transaction that can affect the selling price of the product to external consumers and subsequently affect operating profit. In order to overcome this problem, you can use the transfer pricing method and selling price so that you get the right transfer price and selling price for a business. The results of the transfer price calculation using the cost method and the selling price using the full cost method, the results of the transfer of semi-finished products from the preparation business unit are Rp. 4,900 / unit, while the selling price of the settlement division to external consumers is Rp. 11,020 / unit .Keywords : transfer price, selling price, cost based transfer price, market based transfer price, negotiated transfer price.


VUZF Review ◽  
2021 ◽  
Vol 6 (4) ◽  
pp. 79-90
Author(s):  
Оlena Chukurna ◽  
Larysa Radkevych ◽  
Liliya Rudyk

The article analyzes the causes of offshore jurisdictions and identifies the effects of offshore on national economies. An analysis of the implementation of export-import operations carried out by offshore companies in order to influence the pricing process. The pricing mechanism with affiliates within offshore jurisdictions was presented. It was substantiated the role of offshore banks in the implementation of the pricing mechanism. It was presented the pricing mechanisms within offshore jurisdictions. It has been made an analysis of the impact of transfer pricing within offshore jurisdictions. It was substantiated the economic mechanism of pricing. The international experience of regulation of offshore jurisdictions and the system of controlling the operations of affiliates was analyzed. It was substantiated the mechanisms of functioning of offshore zones and companies operating in offshore jurisdictions. The relationship between agreements concluded within offshore jurisdictions in the following areas is established and substantiated: the agreement is concluded between two independent companies in case of underpricing; the agreement is concluded between the companies connected with the capital relations (affiliated companies) at understatement of the price; agreements between two independent companies in case of overpricing; agreements between affiliated companies in case of overpricing. It was justified the use of the transfer pricing mechanism within offshore jurisdictions. Transfer prices allow you to withdraw capital from the country, as well as hide the profits of companies from taxation. The following ways of minimizing taxation are systematized: registration of a company that concentrates profits in a jurisdiction with lower taxation; concentration of profits in companies that are unprofitable according to management accounting; the use of front companies as sales companies in which profits are concentrated; non-payment of taxes as a result of illegal liquidation of the enterprise - the taxpayer, where the profit is concentrated. The basis of tax minimization is the use in the transaction of a price that deviates from the market.


2019 ◽  
Vol 3 (01) ◽  
Author(s):  
Novi Swandari Budiarso ◽  
Winston Pontoh

Determination of transfer prices and selling prices is not only a matter of large companies. This problem can occur in a type of Small and medium enterprise. But sometimes managers from small and medium businesses do not realize that in their business there is a transfer price transaction that can affect the selling price of the product to external consumers and subsequently affect operating profit. In order to overcome this problem, you can use the transfer pricing method and selling price so that you get the right transfer price and selling price for a business. The results of the transfer price calculation using the cost method and the selling price using the full cost method, the results of the transfer of semi-finished products from the preparation business unit are Rp. 4,900 / unit, while the selling price of the settlement division to external consumers is Rp. 11,020 / unit .Keywords : transfer price, selling price, cost based transfer price, market based transfer price, negotiated transfer price.


2019 ◽  
Vol 32 (2) ◽  
pp. 137-157
Author(s):  
Ivar Friis

ABSTRACT According to organizational economists, the implementation of market-like control mechanisms, such as transfer prices, can never completely replicate the market since “the use of high-powered incentives in firms is inherently subject to corruption” (Williamson 1985, 140). This paper illustrates that this is not necessarily always so. By means of a case study, this paper illustrates that many problems that extant research claims are related to cost-based transfer prices were mitigated through an organizational design that created a quasi-market inside the firm. The paper contributes to extant research in several ways. First, it illustrates that strong incentives are somewhat preserved through an organizational design that fosters competition between product divisions. Second, the paper shows how the specific problems related to a standard variable cost transfer price were mitigated. Finally, the paper highlights the limits of the quasi-market and describes a number of problems that required central intervention.


2019 ◽  
Vol 61 (1) ◽  
pp. 205-231 ◽  
Author(s):  
Ambareen Beebeejaun

Purpose One of the most common forms of international tax avoidance is transfer pricing by multinational enterprises. The research will investigate on the factors that contribute to transfer pricing abuses. At present, there is no substantial and extensive transfer pricing rule in Mauritius. This paper aims to analyse the legal approaches to tackle transfer pricing issues that are undertaken by some countries whose taxation regime is similar to Mauritius. The selected countries are South Africa and UK. The objective behind the comparative study is to come up with the appropriate preventive and corrective measures for Mauritius. Design/methodology/approach The methodology adopted for this research consists of a critical analysis and comparative legal review of the relevant legislation, case law and literature. A minor quantitative analysis of the transfer pricing problem in Mauritius will be conducted, in terms of which interviews will be conducted with officials from different institutions in Mauritius. Findings The study will conclude that the absence of explicit formal rules on transfer pricing allows businesses to use the country to manipulate transfer prices to avoid paying taxes. Therefore, an amendment to Mauritius laws and regulatory framework is required to dissuade multinationals to engage in transfer pricing abuses. The study will conclude that the scope and application of the arm’s length principle needs to be formally set out in legislation and also, the use of Advance Pricing Agreements will also be recommended. Originality/value The research is among the first studies that compare Mauritius legal provisions on transfer pricing with that of South Africa and UK. The research is unique as it intends to provide fruitful recommendation to stakeholders in Mauritius to enhance the existing legal framework on the subject.


2019 ◽  
Vol 15 (2) ◽  
pp. 198-230 ◽  
Author(s):  
Katrin Hummel ◽  
Dieter Pfaff ◽  
Benedikt Bisig

Purpose This paper aims to draw on Adler and Borys’ (1996) concept of an enabling use of bureaucracy to examine how the integration of a single-book tax-compliant transfer pricing system into the management control system is related to the perceived success of that transfer pricing system. Design/methodology/approach Based on survey data from Swiss multinational firms, the authors test a structural equation model. In addition, the authors conduct interviews with executives from three multinational enterprises. Findings The authors find that the integration of a tax-compliant transfer pricing system into the management control system may be perceived to be successful in achieving both tax compliance and internal (control) purposes. This is particularly true when the transfer pricing system is transparent and can be amended in the case of fundamental management control problems. Research limitations/implications The typical shortcomings of a survey-based research apply to this study. Future research could build on this model and more closely investigate the relationship between transfer pricing system integration and an enabling use of the transfer pricing system. Practical implications Based on this study’s findings, the authors recommend that a strong integration of tax-compliant transfer prices into the management control system should be accompanied by internal transparency and the ability to repair the transfer pricing system. Originality/value Prior research on the integration between transfer pricing and management control systems has either been analytical or based on case studies. This cross-sectional analysis provides reliable insights into different levels of integration, use and the success of transfer pricing systems.


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