MIT OpenCourseWare

____________
http://ocw.mit.edu

15.963 Management Accounting and Control

Spring 2007

For information about citing these materials or our Terms of Use, visit: ________________
http://ocw.mit.edu/terms.
15.963 Managerial Accounting and Control

Spring 2007

Prof. Mozaffar Khan

MIT Sloan School of Management

1
 Citibank

Consider corporate overhead costs in California. These

have to be allocated to the branches in California.
One allocation base is the size of the branch, measured as
the number of employees or the square footage of the
branch.
Another allocation base is the profit of the branch.
Suppose $100k of corporate overhead needs to be allocated
to two branches, A and B.
If profits are $300k and $200k respectively in January,
then A is allocated $60k of overhead and B is allocated
$40k, using profit as the allocation base.

2
 Citibank

If profits are $300k and $300k respectively in February,

then A and B are both allocated $50k of overhead, using
profit as the allocation base.
Notice that A becomes better off when B does better.
This is called a non-insulating cost allocation.
If branch square footage were used as the allocation base,
the allocations would be static in this case, and
independent of performance.
This is called an insulating cost allocation.

3
 Citibank

A non-insulating cost allocation system introduces uncontrollability in the

performance of A.
If Bs performance can not be influenced by A, then should A be penalized when B
does poorly?
However, a non-insulating system has the advantage that:
it promotes mutual cooperation and enhances goal alignment across
departments/branches/divisions;
it promotes mutual monitoring, thereby reducing the firms monitoring costs;
it internalizes some externalities, and may help control free-riding for example
(e.g., the benefits from sacrificing customer service for profitability at a branch are
lower);
it allows risk sharing (e.g., B has a lower cost allocation in a bad month such as
January).
In deciding which allocation system to use, weigh the benefits against the costs
in a given setting.

4
 Transfer Pricing

We studied cost allocation earlier. Transfer prices are

essentially cost allocations.
A transfer price is the charge for a service, or intermediate
good, transferred from one subunit to another within an
organization.
In decentralized organizations, decision rights reside in
individual subunits. Transfer prices are used to coordinate
the actions of autonomous subunits.
E.g., airline mechanic
If a transfer price could be charged by the mechanics home
airport, this may have been avoided.

5
 Transfer Pricing

There are two primary purposes of having transfer prices:

international taxation; and
performance measurement / resource allocation.
Consider a multinational operating in the U.S. and France, and assume
the corporate tax rate is higher in the latter.
Automotive engines are manufactured in France and then shipped to
the U.S. where cars are assembled. Costs in France are as follows:
variable cost per engine is $1000;
full cost per engine is $1800;
the market price in France of similar engines is $2000;
From the perspective of the French division, the transfer price (price
charged the U.S. division) should be as high as is allowed (e.g., market
price).

6
 Transfer Pricing

What about from the perspective of the company as a whole?

The higher the transfer price, the lower the profit of the U.S. division
(because the expense is higher), and the higher the profit of the French
division (because the revenue is higher).
If tax rates are higher in France, then the company will end up paying
higher taxes.
To minimize taxes for the firm, most of the profits should be reported in
the U.S. rather than in France.
So the transfer price should be set as low as possible. The U.S. (French)
division will have low expenses (revenues) and high (low) profit.
Notice that overall sales and production costs are being held constant
in this example. Overall profitability is increased simply by charging a
lower transfer price in this case.
In effect, companies try to use transfer prices to shift their income to
lower tax jurisdictions.

7
 Transfer Pricing

Transfer pricing schemes can cost governments billions of

dollars in avoided tax revenues.
U.S. IRS and Japanese National Tax Agency (NTA) have
traditionally been the most vigorous in investigating and
pursuing avoided revenues.
E.g., IRS claimed $170m from Nissan Motors in 1993 for tax
revenues avoided through unrealistically high transfer prices.
Nissan paid, but was refunded this amount by NTA.
In 2000, NTA claimed $170m from Coca Cola Japan over a
transfer pricing dispute. Coca Cola paid, but was refunded this
amount by IRS.
In 2004, IRS fined GlaxoSmithKline $5.2b over a transfer pricing
dispute relating to 1989-1996 profits.

8
 Transfer Pricing

Besides minimizing taxes, transfer prices can also allow

multinationals to circumvent foreign restrictions on the
flow of funds.
In this case, suppose country A has restrictions on outflows. E.g.,
there may be reinvestment requirements, and at some point
reinvestment locally may not be optimal for the firm.
If the division in A purchases from a division in the home country
B, the latter can charge a higher transfer price, which will
effectively circumvent outflow restrictions.

9
 Transfer Pricing

Transfer prices are also important for proper resource allocation.

We know that free goods or services will be overconsumed. Transfer prices
promote responsible consumption.
For example, if departments are not charged for photocopies, then they will use
copiers with disregard for waste.
Typically, this charge comes as a cost allocation (of support services), illustrating
that cost allocations are essentially transfer prices.
On the other hand, if the transfer price is artificially high, there will be
underconsumption, or possibly more expensive outsourcing.
E.g., internal charge might be 15 cents per copy, when the true charge should be 5 cents.
If the market cost is 7 cents, most copies will be made outside, but this reduces firm value.
Transfer prices are important for performance measurement of responsibility
centers.
E.g., for a profit center, how do you determine profits if there is no charge for
internal goods or services?
Because they affect subunit profits, and therefore bonuses, transfer prices are a
frequent source of internal conflict

10
 Transfer Pricing

Consider an intermediate good (w.l.o.g.). What should its transfer

price be?
It can be the market price, full cost, variable cost, or negotiated price.
Using the market price is useful because it forces the selling subunit to
compete for its existence, and promotes efficiency.
However, problems include:
There may be no identical product in the market;
Even if there are, using the market price may overstate the cost. There
may be synergies from internal production that lower the firms cost of
producing the intermediate good below market price.
If variable cost is used, problems include:
The seller does not recover fixed costs.
Seller may therefore reduced fixed investments and raise variable costs,
which may be suboptimal for the firm.

11
 Transfer Pricing

Using full cost allows the seller to recover fixed costs, but
some problems now are:
the seller can pass on its inefficiencies to the buyer (e.g., excess
capacity);
Raises questions about cost allocations (what is in the full cost?).
When costs are stable, a starting point is to set transfer
prices at least at variable cost.
What is the transfer pricing scheme at Del Norte?
Domestically, seller gets market price, and buyer effectively pays
full cost (not market price) because buyer is credited with sellers
profits.

12
 Transfer Pricing

Is DNP better off with Italia buying on the spot market or

internally? They seem to think the latter.
Is tax avoidance the reason?

13
 Transfer Pricing
Contribution margins for DNP Italia and DNP Corporate per ton of corrugated boxes

Italia Spot Purchase KEA

Rev 400 400
Materials 235 385
Conversion 90 90
CM 75 -75

Mill
Rev 385
Variable costs 204
Freight 48
CM 133

Woodlands
Rev ?
Variable costs ?
CM X

Corporate
CM 75 58 + X 14
 Transfer Pricing
After-tax contribution margins for DNP Italia and DNP Corporate per ton of corrugated boxes
Tax rate is 40% on Italian earnings and 0% on U.S. earnings

Italia Spot Purchase KEA

Rev 400 400
Materials 235 385
Conversion 90 90
CM 75 -75
After-tax 45 -45

Mill
Rev 385
Variable costs 204
Freight 48
CM 133
After-tax 133

Woodlands
Rev ?
Variable costs ?
CM X
After-tax X

Corporate
After-tax CM 45 88 + X 15
 Transfer Pricing

What if Deutschland had bid $400 (instead of $550)?

16
 Transfer Pricing

Contribution margins for DNP Deutschland and DNP Corporate per ton of corrugated boxes
Assumes DNP Deutschland bid was $400;

Deutschland Spot Purchase KEA

Rev 400 400
Materials 235 385
Conversion 75 75
CM 90 -60

Mill
Rev 385
Variable costs 204
Freight 48
CM 133

Woodlands
Rev ?
Variable costs ?
CM X

Corporate
CM 90 73 + X 17
 Transfer Pricing

After-tax contribution margins for DNP Deutschland and DNP Corporate per ton of corrugated boxes
Assumes DNP Deutschland bid was $400; Tax rate is 40% on German earnings and 0% on U.S. earnings.

Deutschland Spot Purchase KEA

Rev 400 400
Materials 235 385
Conversion 75 75
CM 90 -60
After-tax 54 -36

Mill
Rev 385
Variable costs 204
Freight 48
CM 133

Woodlands
Rev ?
Variable costs ?
CM X

Corporate
After-tax CM 54 97+X 18
 Transfer Pricing

Deutschland is more efficient (lower conversion costs) than Italia, so

DNP would have been better off if the former had bid $400 and won.
Should DNP have allowed them to compete on the bid, or should it
have coordinated their bids?
How would this coordination work?
Would this effectively be recentralizing decision making?
Why did Deutschland submit such a high bid?
For some unknown reason, it did not seem to want the contract.
Why did Duffy not buy from a DNP mill?
There are indirect costs of having losses on books, including higher
borrowing costs, difficulty in recruitment and retention, reduced trade
credit and lost contracts.

19
 Transfer Pricing

Minor points:
Mill profits credited to Italia show up in a secret little book in San
Francisco. Why is this book effectively hidden from Italian
employees?
One reason is that these books could be subpoenaed by Italian authorities
if they suspect tax avoidance.
This reinforces the idea that the issue here may be tax avoidance by DNP.
The case notes that if a converting plant buys less than budgeted from
a DNP mill then it pays for unused capacity.
This is a control feature of the transfer pricing system, because it
forces accurate forecasting for the budget.
In its absence, buyers will have an incentive to overstate expected
purchases, to ensure availability of supplies.

20