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Offshoring and outsourcing in a global supply chain: impact of the arm’s length regulation on transfer pricing. (English) Zbl 1403.90289

Summary: We consider the structure of a global supply chain for operational decisions in a multinational firm (MNF) with tax considerations. The MNF consists of two divisions: one for production and the other for retailing. While the retail division of the MNF and the market for its product is located in a domestic country, the production division may be located in either the domestic (high-tax) country or a foreign (low-tax) country. When the two divisions of a MNF are co-located in the domestic country, the firm enjoys the benefit of a centralized operational decision on the order quantity to maximize its total profit although there is no tax saving opportunity. On the other hand, a MNF can enjoy a tax saving benefit when offshoring its production division to a low-tax country although its operational decision on the order quantity is decentralized, which is harmful to the supply chain profit due to double marginalization. The MNF may further pursue the low procurement cost of its retail division by allowing the retail division to search for an outsourcing opportunity from an outside supplier. However, outsourcing can hurt the profit of the MNF from the loss of the production division due to competition with outside suppliers. We analyze the trade-offs in the MNF’s optimal choice of supply chain structure. In addition, we incorporate a regulation on the MNF’s internal transaction by tax authorities, which is commonly called the arm’s length regulation. We study how the MNF’s choice of the operational structure of its supply chain changes in consideration of this regulation. Our results suggest that tax considerations deserve attention from managers when designing the supply chain structure.

MSC:

90B30 Production models
90B06 Transportation, logistics and supply chain management
90B50 Management decision making, including multiple objectives
Full Text: DOI

References:

[1] Arya, A.; Mittendorf, B.; Sappington, D., The make-or-buy decision in the presence of a rival: Strategic outsourcing to a common supplier, Management Science, 54, 10, 1747-1758 (2008) · Zbl 1232.90265
[2] Arya, A.; Mittendorf, B.; Yoon, D.-H., Friction in related-party trade when a rival is also a customer, Management Science, 54, 11, 1850-1860 (2008) · Zbl 1232.91371
[3] Autrey, R.; Bova, F., Gray markets and multinational transfer pricing, Accounting Review, 87, 2, 393-421 (2012)
[4] Blöchliger, H., & Pinero Campos, J. (2011). Tax competition between sub-central governments. OECD Working papers on Fiscal Federalism, OECD.; Blöchliger, H., & Pinero Campos, J. (2011). Tax competition between sub-central governments. OECD Working papers on Fiscal Federalism, OECD.
[5] Bonanno, G.; Vickers, J., Vertical separation, The Journal of Industrial Economics, 257-265 (1988)
[6] Deloitte, The forest and the trees - how a tax-aligned supply chain can reduce your structural tax rate, Technical Report (2008), Deloitte
[7] Ernst & Young, 2010 global transfer pricing survey, Technical Report (2010), Ernst & Young
[8] Hammami, R.; Frein, Y., Integration of the profit-split transfer pricing method in the design of global supply chains with a focus on offshoring context, Computers & Industrial Engineering, 76, 243-252 (2014)
[9] Hsu, V.; Zhu, K., Tax-effective supply chain decisions under China’s export-oriented tax policies, Manufacturing & Service Operations Management, 13, 2, 163-179 (2011)
[10] Huh, W. T.; Park, K. S., Impact of transfer pricing methods for tax purposes on supply chain performance under demand uncertainty, Naval Research Logistics, 60, 4, 269-293 (2013) · Zbl 1410.90027
[11] Jansen, J., Coexistence of strategic vertical separation and integration, International Journal of Industrial Organization, 21, 5, 699-716 (2003)
[12] Kim, K.-T.; Rhee, S.-K.; Oh, J., The strategic role evolution of foreign automotive parts subsidiaries in China, International Journal of Operations & Production Management, 31, 1, 31-55 (2011)
[13] Kouvelis, P.; Milner, J., Supply chain capacity and outsourcing decisions: the dynamic interplay of demand and supply uncertainty, IIE Transactions, 34, 717-728 (2002)
[14] Kwok, H. L.; Jianmei, Z., Drivers and obstacles of outsourcing practices in china, International Journal of Physical Distribution & Logistics Management, 36, 10, 776-792 (2006)
[15] Li, C., Sourcing for supplier effort and competition: Design of the supply base and pricing mechanism, Management Science, 59, 6, 1389-1406 (2013)
[16] Li, Y.; Lim, A.; Rodrigues, B., Global sourcing using local content tariff rules, IIE Transactions, 39, 5, 425-437 (2007)
[17] Liu, Z.; Nagurney, A., Supply chain outsourcing under exchange rate risk and competition, Omega, 39, 5, 539-549 (2011)
[18] Matsui, K., Intrafirm trade, arm’s-length transfer pricing rule, and coordination failure, European Journal of Operational Research, 212, 3, 570-582 (2011) · Zbl 1237.91162
[19] OECD (2008). Transfer pricing aspects of business restructurings: Discussion draft for public comment. Technical Report, OECD.; OECD (2008). Transfer pricing aspects of business restructurings: Discussion draft for public comment. Technical Report, OECD.
[20] Petruzzi, N. C.; Dada, M., Pricing and the newsvendor problem: A review with extensions, Operations Research, 47, 2, 183-194 (1999) · Zbl 1005.90546
[21] Shunko, M.; Debo, L.; Gavirneni, S., Transfer pricing and sourcing strategies for multinational firms, Production and Operations Management, 23, 12, 2043-2057 (2014)
[22] Shunko, M.; Gavirneni, S., Role of transfer prices in global supply chains with random demands, Journal of Industrial and Management Optimization, 3, 1, 99-117 (2007) · Zbl 1165.90338
[23] Shunko, M.; Hung, D.; Tsay, A., Supply chain strategies and international tax arbitrage, Production and Operations Management, 26, 2, 231-251 (2017)
[24] Sisco, C.; Bhorn, B.; Pruzan-Jorgensen, P. M.; Prepscius, J.; Booth, V., Supply chains and the OECD guidelines for multinational enterprises, Proceedings of the tenth OECD roundtable on corporate social responsibility conference (2010)
[25] Swinney, R.; Netessine, S., Long-term contracts under the threat of supplier default, Manufacturing & Service Operations Management, 11, 1, 109-127 (2009)
[26] Vidal, C.; Goetschalckx, M., A global supply chain model with transfer pricing and transportation cost allocation, European Journal of Operational Research, 129, 1, 134-158 (2001) · Zbl 0990.90008
[27] Wang, Z.; Gao, W.; Mukhopadhyay, S., Impact of taxation on international transfer pricing and offshoring decision, Annals of Operations Research, 240, 2, 683-707 (2016) · Zbl 1360.90148
[28] Webber, S., Escaping the US tax system: From corporate inversions to re-domiciling, Tax Notes International, 63, 4, 273-295 (2011)
[29] Xiao, W.; Hsu, V.; Hu, Q., Manufacturing capacity decisions with demand uncertainty and tax cross-crediting, Manufacturing & Service Operations Management, 17, 3, 384-398 (2015)
[30] Yang, F. X.; Zhang, R. Q.; Zhu, K., Should purchasing activities be outsourced along with production?, European Journal of Operational Research, 257, 468-482 (2017) · Zbl 1394.90260
[31] Yao, J.-T., The arm’s length principle, transfer pricing, and location choices, Journal of Economics and Business, 65, 1-13 (2013)
[32] Zhen, L., A three-stage optimization model for production and outsourcing under China’s export-oriented tax policies, Transportation Research Part E: Logistics and Transportation Review, 69, 1-20 (2014)
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