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ABSTRACT

Transfer pricing stands at the heart of a MNE management control system. We review the theories of TCE and RBV and develop antecedents and consequences of transfer prices based on these theories. We propose viewing transfer pricing decisions through a TCE and RBV value chain framework. We review a sample of transfer pricing literature based on this theoretical perspective and show how it fits within our framework. Our framework suggests that setting transfer pricing policy is indeed a complex problem that includes many factors and has many consequences, some of which may be at odds with each other. We give some suggestions for future research based on this framework.

4. Conclusions and recommendations

MNEs must make many strategic and tactical decisions in order to coordinate their intraorganizational value chain activities. Strategic decisions include but are not limited to: what product to produce; where to produce it; and how to get the most out of limited resources. Tactical decisions include, but are not limited to: how to create incentives to coordinate the value chain; how to control quality across the value chain; how to limit transaction risks; and how to distribute income among divisions to fairly evaluate and motivate mangers in a decentralized organization. Transfer pricing policy is used to mediate these activities affecting both strategic and tactical decisions. Transfer pricing policy is affected by the nature of the value chain, including: the products and services that are produced; markets; environmental factors including taxes and regulations; power and dependence dynamics; resources; and governance structures including divisional relationships. Transfer pricing policy affects the coordination of value chain activities, opportunistic behavior, the location of resources, risks and motivation. For these reasons transfer pricing decisions are of paramount importance to a MNE. Moreover, in addition to these factors, there are often multiple objectives to consider which make MNE transfer price policy decisions especially complex.