Chapter 19 – Strategic Performance Measurement: Investment Centers & Transfer Pricing
when the units have a history of significant conflict and negotiation can result in an agreed-
upon price. The limitation is that this method can reduce the autonomy of the units.
e. Text Exhibit 19.9 provides a useful summary of the primary advantages and disadvantages
associated with each of the above-four transfer pricing alternatives.
C. Choosing the Right Transfer Pricing Alternative. The three key factors to consider in deciding
whether to make internal transfers, and if so, in setting the transfer price are presented in text Exhibit
19.10 and are summarized as follows:
a. Is there an outside supplier? If not, there is no transfer price, and the best transfer price is based
on cost or negotiated price. If there is an outside supplier, we must consider the relationship of
the inside seller’s variable cost to the market price of the outside supplier by answering the next
question.
order to the internal buyer at a transfer price between variable cost and market price. If the
selling unit is at full capacity, we must determine and compare the cost savings of internal sales
versus the selling division’s opportunity cost of lost sales. If the cost savings to the inside buyer
are higher than the cost of lost sales to the seller, the buying unit should buy inside, and the
proper transfer price should be the market price.
This three-question analysis is from top management’s perspective and is thus the desired outcome if the
units make these decisions autonomously. A good approach that preserves much of the units’ autonomy is
to set clear guidelines regarding top management’s objectives on transfer pricing.
The discussion here should conclude with a presentation and discussion of the general transfer-pricing
model, as well as a discussion regarding practical difficulties in implementing this general model. Of
particular merit is relating the general model to the definition of “relevant cost” as defined and used in
Chapter 11 (Decision Making) of the text, that is, relevant cost = out-of-pocket costs + opportunity costs.
D. International Tax Issues in Transfer Pricing. Most countries now accept the Organization of
Economic Cooperation and Development’s model treaty, which calls for transfer pricing to be adjusted
using the arm’s-length standard, that is, to a price that unrelated parties would have set. The model treaty
price by using the sales price of similar products made by unrelated firms.
b. Resale price method. The resale price method is based on determining an appropriate markup
based on gross profits of unrelated firms selling similar products.
19-10