Chapter 19 – Strategic Performance Measurement: Investment Centers
19–30
external transfer. There is the cost of risk the seller might incur OR avoid by selling internally that,
according to the authors, can be used to by the seller in terms of establishing an “arm’s–length price.”
Further, the authors suggest that this ability “to adjust for risk permits a wider range of (acceptable)
Comments:
1. It is not clear what the source of this recommendation by the authors is. For example, is it the
opinion of the authors? Is it statutorily backed?
2. The choice of the $50 amount as the example offered by the authors is interesting. Might it (that is,
the low dollar amount) suggest that the leeway under the authors’ recommendation is rather limited
in terms of its impact on world-wide taxes paid?
3. It is also interesting that in discussing Table 3 the authors do not state explicitly that internal cost
savings realized because of internal transfers (i.e., situations where there are synergies associated
with internal transfers), these cost reductions can be used for tax purposes to justify a transfer price
below external market price. This possibility is not raised until later in the article when the authors
state: “As discussed in case 3, tax law allows transfer-price differences based on avoidable costs,
such as bad debts.”
In Table 4, the authors examine the situation where (similar to the case illustrated in Table 2) the
selling division is operating at less than capacity, and (similar to the case illustrated in Table 3) there
are non-comparable circumstances regarding internal versus external transfers. According to the
authors, the opportunity that exists in this context is basically the same as the case 3 (above).
A summary analysis by the authors is presented in Table 5 in the article.
5. What recommendation do the authors offer on the basis of the analysis contained in Tables 1–5
and the accompany discussion?
Table 5 indicates that in four of six situations, the theoretical (marginal costing) or managerial
accounting recommendation for setting transfer prices is inconsistent with the arm’s-length
requirement for international tax purposes. When the selling division has idle capacity, transfer prices
set using a marginal-costing (i.e., economic) approach fail to satisfy tax requirements. When the
selling division has no idle capacity and economic circumstances for internal and external transfers are
comparable, then the marginal costing approach is acceptable for tax purposes.
Given the summary in Table 5, the authors recommend that “all transfer prices be set as if the firm
were operating a fully capacity” (i.e., as if idle capacity were zero). Two justifications of this
recommendation are offered by the authors: