Key Takeaways
- Transfer prices are internal prices charged between divisions for goods or services within the same organization.
- Market-based transfer prices work best when external markets exist; cost-based prices are used when markets are unavailable.
- Negotiated transfer prices allow divisions to bargain within a range, promoting autonomy but potentially causing conflicts.
- The transfer pricing decision affects divisional profits, managerial incentives, and overall company optimization.
- International transfer pricing involves tax implications, customs duties, and regulations that add complexity.
Transfer Pricing
Quick Answer: Transfer pricing sets the internal price charged when one division sells goods or services to another division within the same company. The three main methods are market-based (external market price), cost-based (variable or full cost), and negotiated (divisions bargain). The ideal transfer price promotes goal congruence, divisional autonomy, and accurate performance evaluation.
Transfer pricing is a critical issue for decentralized organizations with multiple divisions that trade with each other. The transfer price affects how profits are distributed between divisions and can influence managerial decisions about internal vs. external transactions.
Why Transfer Pricing Matters
Objectives of Transfer Pricing
| Objective | Description |
|---|---|
| Goal congruence | Division decisions align with company-wide optimization |
| Performance evaluation | Fairly measure divisional profitability |
| Autonomy | Preserve divisional independence and motivation |
| Tax optimization | Minimize overall tax burden (for international) |
Transfer Pricing Conflicts
Consider this example:
- Selling Division wants a high transfer price → Higher divisional profit
- Buying Division wants a low transfer price → Higher divisional profit
- Company wants both divisions profitable AND optimal decisions
Transfer Pricing Methods
1. Market-Based Transfer Pricing
Definition: Use the price at which the product could be sold to external customers.
Formula:
Advantages:
- Objective and verifiable
- Simulates arm's-length transactions
- Encourages efficiency (must compete with external suppliers)
- Easy performance evaluation
Disadvantages:
- Market price may not exist for specialized products
- Market prices may be volatile
- Doesn't consider internal synergies
Best Used When:
- Active external market exists
- Selling division is at full capacity
- Intermediate product is standardized
2. Cost-Based Transfer Pricing
Transfer prices based on the selling division's costs.
Variable Cost
Formula:
Advantages:
- Simple to calculate
- Optimal for short-term decisions
- No need for external market data
Disadvantages:
- Selling division earns zero margin
- No incentive to control variable costs
- Demotivates selling division managers
Full Cost (Variable + Fixed)
Formula:
Advantages:
- Ensures all costs are recovered
- Better for long-term decisions
Disadvantages:
- Includes arbitrary fixed cost allocations
- May lead to suboptimal decisions
- Can double-count fixed costs
Cost-Plus
Formula:
Advantages:
- Selling division earns a profit
- Motivates cost control
- Balances interests of both divisions
Disadvantages:
- Markup percentage is arbitrary
- Still requires cost accuracy
3. Negotiated Transfer Pricing
Definition: Divisions negotiate the transfer price within acceptable ranges.
Range for Negotiation:
If Minimum ≤ Maximum, mutually beneficial trade is possible.
Advantages:
- Preserves divisional autonomy
- Both parties have incentive to negotiate fairly
- Can account for unique circumstances
Disadvantages:
- Time-consuming negotiation process
- Depends on negotiating skills
- May create inter-divisional conflict
- Requires clear information sharing
4. Dual Pricing
Definition: Different transfer prices for the selling and buying divisions.
How It Works:
- Selling division records revenue at market price
- Buying division records cost at variable cost
- Corporate eliminates the difference
Advantages:
- Motivates both divisions
- Selling division earns fair profit
- Buying division makes optimal decisions
Disadvantages:
- Complex accounting
- Inflates combined divisional profits
- Requires corporate adjustment
The General Transfer Pricing Rule
Formula for Optimal Transfer Price:
Where opportunity cost is the contribution margin lost if the product is transferred internally instead of sold externally.
Scenarios:
| Situation | Opportunity Cost | Transfer Price |
|---|---|---|
| Excess capacity, no external market | $0 | Variable cost |
| Excess capacity, external market exists | $0 | Variable cost (minimum) |
| Full capacity, can sell all externally | Market price - Variable cost | Market price |
| Partial capacity constraint | Lost CM on units not sold externally | Variable cost + Lost CM |
Transfer Pricing Example
Situation:
- Selling Division: Variable cost = $30, Full cost = $45, Market price = $50
- Selling Division capacity: 10,000 units
- Internal demand: 2,000 units
- External demand: 9,000 units (at $50)
Analysis:
- If the Selling Division transfers 2,000 units internally, it can only sell 8,000 externally
- Lost external sales = 1,000 units (since 2,000 + 9,000 > 10,000)
- Opportunity cost per unit = $50 - $30 = $20
Optimal Transfer Price:
At full capacity with excess external demand, the transfer price equals market price.
International Transfer Pricing
International transfers add complexity due to:
Tax Implications
| Scenario | Company Strategy | Regulatory Response |
|---|---|---|
| High-tax country selling division | Set low transfer price | Arm's-length requirement |
| Low-tax country selling division | Set high transfer price | Transfer pricing regulations |
| Countries with different tax rates | Shift profits to low-tax jurisdiction | Advance pricing agreements |
Regulatory Requirements
- Arm's-length principle: Price must be what unrelated parties would charge
- Documentation requirements: Detailed justification for transfer prices
- Advance Pricing Agreements (APAs): Pre-approved transfer pricing methods
- Country-by-country reporting: Multinational disclosure requirements
Other International Considerations
| Factor | Impact on Transfer Price |
|---|---|
| Customs duties | May prefer lower prices to reduce import duties |
| Currency restrictions | May use transfer pricing to repatriate funds |
| Import quotas | Volume-based restrictions affect decisions |
| Political risk | Transfer funds out of risky locations |
Choosing a Transfer Pricing Method
| Criterion | Market-Based | Cost-Based | Negotiated |
|---|---|---|---|
| External market exists | Best | Acceptable | Acceptable |
| No external market | Not possible | Best | Acceptable |
| Divisional autonomy | High | Low | High |
| Goal congruence | High | Variable | Variable |
| Administrative cost | Low | Low | High |
| Performance evaluation | Excellent | Poor | Good |
Division A produces a component with a variable cost of $25 and sells it externally for $40. Division B can buy the same component externally for $38. If Division A has excess capacity, what transfer price range would allow a mutually beneficial internal transfer?
The general transfer pricing rule states that the optimal transfer price equals:
Which transfer pricing method would be LEAST appropriate when no external market exists for the intermediate product?
A multinational company shifting profits to a low-tax jurisdiction through transfer pricing would most likely: