Multinational transfer pricing, effect of alternative transfer-pricing methods, global income tax minimization. User Friendly Computer, Inc., with headquarters in San Francisco, manufactures and sells a desktop computer. User Friendly has three divisions, each of which is located in a different country:

a. China Division—manufactures memory devices and keyboards

b. South Korea Division—assembles desktop computers using internally manufactured parts and memory devices and keyboards from the China Division

c. U.S. Division—packages and distributes desktop computers

Each division is run as a profit center. The costs for the work done in each division for a single desktop computer are as follows:

• Chinese income tax rate on China Division’s operating income: 40%
• South Korean income tax rate on South Korea Division’s operating income: 20%
• U.S. income tax rate on U.S. Division’s operating income: 30%

Each desktop computer is sold to retail outlets in the United States for $3,200. Assume that the current foreign exchange rates are:

    8yuan  = $1 U.S.

     1,200 won  = $1 U.S.

Both the China and the South Korea divisions sell part of their production under a private label. The China Division sells the comparable memory/keyboard package used in each User Friendly desktop computer to a Chinese manufacturer for 3,600 yuan. The South Korea Division sells the comparable desktop computer to a South Korean distributor for 1,560,000 won.

1. Calculate the after-tax operating income per unit earned by each division under the following transfer-pricing methods: (a) market price, (b) 200% of full cost, and (c) 300% of variable cost (Income taxes are not included in the computation of the cost-based transfer prices.)

2. Which transfer-pricing method(s) will maximize the after-tax operating income per unit of User Friendly Computer?

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Variable cost = 1,000 yuan China Division: Fixed cost = 1,800 yuan Variable cost =360,000 won South Korea Division: Fixed cost = 480,000 won U.S. Division: Variable cost = $100 Fixed cost = $200