Multinational transfer pricing and taxation.
Vik-Giger Corporation, headquartered in the U.S., manufactures state-of-the-art
milling machines. It has two marketing subsidiaries, one in Brazil and one in
Switzerland, that sell its products. Vik-Giger is considering building one new
machine, at a cost of $500,000. There is no market for the equipment in the
United States. The equipment can be sold in Brazil for $1,000,000, but the
Brazilian subsidiary would incur transportation and modification costs of
$200,000. Alternatively, the equipment can be sold in Switzerland for $950,000,
but the Swill subsidiary would incur transportation and modification costs of
$250,000. The U.S. company can sell the equipment either to its Brazilian
subsidiary or to its Swiss subsidiary but not to both. Vik-Giger Corporation and
its subsidiaries operate in a very decentralized manner. Managers in each
company have considerable autonomy, with each division manager interested in
maximizing his or her own division’s income.
Questions:
- From the viewpoint of Vik-Giger and its subsidiaries taken together, should
Vik-Giger Corporation manufacture the equipment?
- (a) If it does, where should it sell the equipment to maximize corporate operating income?
- (b) What would the operating income for Vik-Giger and its subsidiaries be from the sale? Ignore any income tax effects.
- What range of transfer prices will result in achieving the actions determined to be optimal in requirement 1? Explain your answer.
- The effective income tax rates for this transaction follow: 40\% in the
United States, 60\% in Brazil, and 15\% in Switzerland. The tax authorities in
the three countries are uncertain about the cost of the intermediate product
and will allow any transfer price between $500,000 and $700,000. If Vik-Giger
and its subsidiaries want to maximize after-tax operating income:
- (a) should the equipment be manufactured and
- (b) where and at what price should it be transferred?
- Now suppose each manager acts autonomously to maximize his or her own
subsidiary’s after-tax operating income. The tax authorities will allow
transfer prices only between $500,000 and $700,000. Which subsidiary will get
the product and at what price? Is your answer the same as your answer in
3? Explain why or why not.