Question: 2 3 - 2 0 Multinational transfer pricing, effect o f alternative transfer - pricing methods, global income tax minimization. People Able Computer, Inc., with

23-20 Multinational transfer pricing, effect of alternative transfer-pricing methods, global income tax
minimization. People Able Computer, Inc., with headquarters in San Francisco, manufactures and sells a
desktop computer. People Able 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 locally manufactured parts, along with
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:
China division:
South Korea division:
U.S. division:
Variable cost =1,000 yuan
Fixed cost =1,800 yuan
Variable cost =360,000 won
Fixed cost =480,000 won
Variable cost =$100
Fixed cost =$200
Chinese income tax rate on the China division's operating income: 40%
South Korean income tax rate on the South Korea division's operating income: 20%
U.S. income tax rate on the U.S. division's operating income: 28%
Each desktop computer is sold to retail outlets in the United States for $3,200. Assume that the current foreign
exchange rates are as follows:
8 yuan =$1U.S.
1,200 won =$1U.S.
Both the China and the South Korea divisions sell part of their production under a private label. The China
division sells the comparable memorykeyboard package used in each People Able desktop computer toa
Chinese manufacturer for 3,600 yuan. The South Korea division sells the comparable desktop computer toa
South Korean distributor for 1,560,000 won.
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.)
Which transfer-pricing method(s) will maximize the after-tax operating income per unit of People Able
Computer?
2 3 - 2 0 Multinational transfer pricing, effect

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