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52
_____________________________________________________________
Professor Julio B. CLEMPNER, PhD
E-mail: julio@clempner.name
Instituto Politécnico Nacional
Professor Alexander S. POZNYAK, PhD
E-mail: apoznyak@ctrl.cinvestav.mx
Center for Research and Advanced Studies
1.Introduction
1.1. Brief review
The problem of transfer pricing employs optimization goals to set internal
prices of goods or services that are sold between subsidiaries or divisions of a firm [8].
Several pricing policies are followed in practice: marginal cost, market price, average
cost, etc. and particular solutions (negotiations) adapted to specific situations. In a
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Related works presented in the literature have identified that the transfer pricing
problem is inherently a multi-objective problem for optimally and developed transfer
pricing methodologies based on mathematical programming and game theory. The
seminal paper on transfer pricing was presented by Hirshleifer[15] who considering a
system that focus on the maximization of divisional income suggested that the precise
transfer price for a good is the marginal cost of the producing division. Horst[16]
explored the profit-maximizing strategy for a monopolistic firm selling to two national
markets simultaneously. Kassicieh[18] presented a model of transfer pricing that is
developed further to include all of the issues that affect the total profits of the
multinational corporation through transfer prices and expanded to include economic
externalities and interdependencies such as nonlinear cost functions and functional
relationships among demand, supply and transfer prices. Luft and Libby[22] examined
experienced managers' judgments about the effects of market price and accounting
profit information on negotiated transfer prices. Lakhal[19] developed a method using a
mathematical programming model and providing companies an opportunity to work
proactively with the internal revenue service in a cooperative manner in order to avoid
costly audit and litigation. Lakhal et al.[20] proposed a framework and methodology for
profit sharing and transfer-pricing between network companies presenting a paradigm
that enables maximization of operating profits by the manufacturing-network in its
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larger supply chain, suggesting a departure from the model that maximizes profits for
the individual company within the sphere of its own supply chain. Shunko and
Gavirneni[25] showed that randomness in a supply chain magnifies the impact of
transfer prices and analyzed possible reasons behind this behavior and summarized the
impact of various supply chain parameters on the magnitude of profit improvement.
Rosenthal[24] developed a cooperative game that provides transfer prices for the
intermediate products in a vertically integrated supply chain. Leng and Parlarb [21]
considered the transfer pricing decision for a multidivisional firm with an upstream
division and multiple downstream divisions solving the problem using a cooperative
game which computes the Shapley value-based transfer prices for the firm. Huh and
Park[17] compared the supply chain profits for transfer pricing suggesting that the
firm-wide and divisional profits tend to be higher under the cost-plus method than they
are under the resale-price method. Hammami and Frein[14] developed an optimization
model for supply chain addressing decisions, costs, and complexity factors integrating
transfer pricing to derive a series of insights that may be helpful for companies and
governments. Clempner and Poznyak[8] proposed a solution to the transfer pricing
problem from the point of view of the Nash bargaining game theory approach.
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The remainder of the paper is organized as follows. The next Section suggests
the formulation of the problem for transfer pricing. Section 3 presents the cooperative
game model describing the Pareto front, the restrictions over jurisdictions imposed by
governments and the strong Nash equilibrium of the problem. Section 4 describes the
regularized penalty function optimization method. Section 5 concludes the paper with
some remarks and future work. The appendix presents the proofs of the theorems.
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1 This example describes the treatment for transfer pricing cost-taxation purposes and the aim is
to illustrate the key points to take into consideration.
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costs and the taxes, and we use the general form cl (ql ) and r l ( pl ql ) for our analysis.
Then, our variables are defined as follows:
Market prices p l for one intermediate good (sold from l to l 1 ).
Quantities q l of intermediate goodl shipped fromlto l 1 for l = 1,...,N 1 ;
Production costs cl (ql ) := cl ql , cl 0 (e.g.: transactional costs, raw materials,
components, and their per period inventory costs in dollars) at each level l = 1, N ;
Taxes r l ( pl ql ) := rl pl ql , rl 0, at each level l = 1, N .
We suppose that all the division are located in different marketing areas,
therefore they face independent demands q l , costs cl (ql ) and taxes r l ( pl ql ) . Then,
the division's utility U l for each level l = 1, N is given by
U 1 ( p1 , q1 ) = p1q1 c1 (q1 ) r1 ( p1q1 )
U l ( p l , p l 1 , q l ) = p l p l 1 q l c l (q l ) r l ( p l q l )for l = 2,..., N
where l = 1 represents the first division and l = 2,...,N the rest of the divisions on the
vertically integrated supply chain.
N
S N := RN : l 0,1, l = 1
l =1
with the Pareto front given by
U(v ) = U 1 v ,U 2 v ,...,U N v
3.2. Constraints
Multidivisional firms look for coordinate its divisions in order to maximize the
global profit of the firm after cost-tax through the transfer pricing decision. For instance,
if a given upstream division is located in a lower-cost-tax jurisdiction, then increasing
the transfer price results in an increase in the firm's after-cost-tax profit. To prevent
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q , q
N
p l pl , pl , q l ql , ql , Padm := l
l
adm := l
l
l =1 l =1
Remark 2. For practical reasons and improving the flexibility of the model we
propose to establish bounds on both p and q .
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N
W v | = U(v ) =
ú
U p
l
l l
, p l 1 , q l
l =1
Remark 4. The proposed model can find the collaborative equilibrium point
of both, p by fixing the value of q and, p and q simultaneously, depending on
the case.
4. Regularization method
4.1. Regularized poly-linear programming problem
N N N N N N
(6)
N 1 c
j1 =1 j2 =1 j N 1 =1
j1 ,, j N 1 x j1 xj
N 1
N c
j1 =1 j2 =1 j N =1
j1 ,, j N x j x j min
1 N x X adm
has a unique solution since the optimized function (8) is strongly convex [23] if > 0 .
Notice also that
Fk , x, u = arg F , x, u
~
arg min min
xX adm ,u 0 xX adm ,u 0
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F , x, u := f ( x)
1
2
V0 x b0
2
1
2
V1 x b1 u
2
2
x u
2
2
(10)
tend to the set X of all solutions of the original optimization problem (7), that is,
x , , u , ; X 0
0
(11)
where a; X is the Hausdorff distance defined as
a; X = min a x .
2
x X
Below we define exactly how the parameters and should tend to zero to
provide the property (11).
Then
xn := x n , n x , un := u n , n u (14)
n n
where x X is the solution of the original problem (7) with the minimal weighted
norm which is unique, i.e.,
x x for all x X
(15)
and
u = b1 V1x. (16)
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Corolary 7. Under the assumptions of the Theorem 6 above there exist positive
constants C and C such that
xn xm un um C n m C n m . (17)
Consider the following recurrent procedure for finding the extremal point
x
z :
u
x
(18)
zn = zn 1 n F , zn 1 , z :=
z n n u
z n n F
, xn 1 , un 1
V1 xn1 b1 un1
u n n
Remark 8. (convergence of the gradient method )If
n n 1 n n 1
n n = , 0, n
n n n n
0
n
n=0 (19)
then
2
Wn := z n z n 0.
n
(20)
Let us select the parameters of the algorithm (18) as follows:
0 if n n0 0 if n < n0
n = 1 ln n n0
0
if n > n0 , n = if n n0
0
1 n n0 1 n n0
(21)
0 if n < n0
0
n = if nn , , , > 0, 0 , 0 , 0 > 0
1 n n0 0
.
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Then
un = o n1 (25)
5. Numerical example
5.1. A priori data required for the solution of the problem
pl pl , pl , , ql ql , ql , l = 1,...,N ; p1 1000,9000 ,
p2 4100,15000 , p3 10100,340000 , q1 50,300 , q 2 100,500 , q3 150,700
cl (ql ) := cl ql , l 0, l = 1,...,N ; c1 = 0.1, c2 = 0.1, c3 = 0.1.
r l ( pl ql ) := rl pl ql , l = 1,...,N . r1 = 0.1, r2 = 0.2 , r1 = 0.3.
p10 = 4500; p02 = 10000; p03 = 180000; q10 = 150; q02 = 300; q03 = 450.
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N
W v | := 1U 1 p l , q l U p , pl
l l l 1
, ql
l =2
v = ( p, q) : p = ( p1 ,..., pN ) andq = (q1 ,..., qN ) T
T
N
S N := R N : l 0,1, l = 1
l =1
in the form of a poly-linear function optimization with linear constraints, namely,
W v | max Aineqv beq , v 0
v
where (for N = 3 )
1 0 0 0 0 0 p 1
0 2
1 0 0 p
1 p3
1 q 1
2
1 0 q
q3
=
0 0 1
Aineq , bineq = 1
1 0 0 p
1 p2
1 p
3
1 q1
1 q 2
0 3
0 1 q
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For maximizing the utility let us consider the following recurrent procedure for
v
finding the extremal point z :
u
v
z n = z n 1 n F , z n 1 , z :=
z n n
u (29)
zi if zi 0
where zi = and the first-order derivative of F , zn1
0 if zi < 0 n n
1 q1 r1q1 2 (q 2 )
2 q 2 r2 q 2 3 (q 3 )
3 q 3 r3 q 3
F v , u p c r p
1 1 1 1
F , z n 1 =
, n 1 n 1
=
v n n
z n n F
n , n v n 1 , u n 1
2 2 2 2
p p
2 c r
u 3 p c r p
3 3 3 3
========== =====
Aineqv bineq 1 u
Figure 4 presents the Pareto front of the transfer pricing. Computing the strong Nash
equilibrium, we have that = 0.0256,0.0 256,0.9487 , p = 0.0505,0.1497,1.9645105 ,
q = 177.3265,409.3044,641.2830, U = 0.0805,0.2 837,7.8584 10 7 , W = 7.4648 10 7 .
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The transfer pricing problem results essential in resource allocation and global
firm profit for a multidivisional firm which employs optimization goals to set internal
prices of goods that are sold between subsidiaries or divisions of the firm. Usually, each
division estimates the revenues or profits of each opportunity and selects the best
opportunity. As a result, the transfer prices system focuses on the maximization of
divisional income, leading the divisions to achieve the goals of the firm through
sub-optimization. However, sub-optimizations by individual divisions do not result in
an optimum for the firm.This paper presented a new modeling framework for transfer
pricing schemes based on cooperative game theory considering cost and tax policies.
The study provided decision makers with a useful tool for supporting the design of
global strategies for transfer-pricing, considering different variables of optimization
(price and quantity) and establishes a flexible model after cost-taxes profitable
configuration. The proposed model integrate financial issues for vertically integrated
supply chains. There are relatively few models of global profit maximization reported in
the literature for large-scale organizations. Accordingly, we consider that the
implementation of transfer pricing models for global profit maximization represents a
fundamental opportunity that must be seriously considered by large-scale
multidivisional firms.
We proposed a method for computing the transfer pricing for a multidivisional
firm based on a multi-objective approach for representing a cooperative game. For
computing the strong Nash equilibrium we employed the minimal distance to the utopia
point. We suggested the use of the Tikhonov's regularization to guarantee the
convergence to a single (strong) equilibrium point. We proposed a method based on a
penalized programming approach for computing the regularized strategies of the game.
We developed a programming method to solve the successive single-objective
constrained problems that arise from taking the regularized functional of the game. In
addition, we implemented a recurrent procedure based on the gradient method to solve
the regularized problem and finding the Pareto optimal strategies. We proved that in the
regularized problem the functional of the game decreases and finally converges, proving
the existence and uniqueness of strong Nash equilibrium. We also presented the
convergence conditions and compute the estimate rate of convergence of variables
and corresponding to the step size parameter of the regularized penalty method. We
provided all the details needed to implement the method in an efficient and numerically
stable way.
In terms of future work, there exist a number of challenges left to address. One
interesting technical challenge is that of developing a numerical method for
implementing the results presented in this paper. We also are considering to extend the
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Appendix A.
Proof. [Teorem 6]
First, let us prove that the Hessian matrix H associated with the penalty
function (10) is strictly positive definite for any positive and , i.e., we prove that
M1
for all x R N and u R
2 2
2 F , x, u F , x, u
H = 2 x u x >0 (A.1)
2
F
xu , x , u F , x , u
u 2
To prove that, by the Schur lemma [23], it is necessary and sufficient to prove that
2 2
F , x, u > 0, F , x, u > 0
x 2 u 2
1
2 2 2 2
F , x , u > F , x , u 2 ,
F x , u F , x, u (A.2)
x 2 ux u xu
We have
2 2
F x, u = 2 f ( x) V0TV0 V1TV1 I N N
2 ,
x x
2
2 f ( x) I N N 1 I N N > 0 n > 0
x
2 2
:= min min 2 f ( x) 2 F , x, u = I M M > 0
xX adm
x u
1 1
2
implying, f ( x) V0TV0 V1TV1 I NN > 0 which holds for any > 0 by the
x 2 1
condition (13) since
I NN V0TV0
1
V1TV1 1 I NN = 1 o(1) I NN > 0
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So, H > 0 which means that the penalty function (10) is strongly convex
and, hence, has a unique minimal point defined below as x , and u , .By the
strictly convexity property (30) for any z := x and any vector
u
x = x n , n
for the function F , x, u = F , z we have
zn : n
u
n = u n , n
0 z n z
z n n
T
F , z n = n xn x
T
x
f xn
T
T
T
V0 xn x V0 xn b0 V1 xn x V1 xn b1 un n xn x xn
u u V x b 1 u
n
T
1 n 1
n
(A.3)
Selecting in (A.3) x := x X ( x is one of admissible solutions such that V0 x = b0 )
and u := b1 V1xn we obtain
0 n xn x T
x
f xn V0 xn x 2
V1 xn x 2
T
n xn x xn
V1 xn x 2 2
V1 xn b1 1 u n xn x xn u n b1 V1 xn u n .
T T
(A.4)
which means that the sequence un is bounded. In view of this and taking into account
that by the supposition (13) n
0, from (A.4) it follows
n n
T
xn x xn
Const = limsup
n 1 1 n
n u b V x u
T
n
(A.5)
limsup
1
n
2
V0 xn b0 V1 xn x 2
1 n 1 V1 xn b1 1 n u n
2
n
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2
V0 xn b0 V1 xn x 2
1 n 1 V1 xn b1 1 n un = O n
2
(A.6)
and
V0 x b0 = 0, V1x V1x = V1x
b1 u =0
where x X is a partial limit of the sequence xn which, obviousely, may be not
unique. The vector u is also a partial limit of the sequence un .Denote by x̂n the
projection of xn to the set X adm , namely,
xˆn = PrX
adm
x
n (A.7)
and show that
xn xˆn C n , C = const > 0. (A.8)
From (A.6) we have
V1 xn b1 un C1 n , C1 = const > 0
implying
V1 xn b1 C1 n e un C1 n e, e = 1
where the vector inequality is treated in component-wise sense. Therefore
min x y := d n .
2
xn xˆn
2
max
V1x b1C1 n e, xX adm yX adm
x n x
~
we have
x=
1 n
C1 n
x b1
V1~ min V1 x b1 j e V1 x b1 0
C1 n min V1 x b1 j j =1,..., M1
j =1,..., M1
and therefore
2
x n x ~
~ n2
d n
2
max x = max x x C2 n , 0 < C2 < .
~
x b1 0,~
V1~ xXadm 1 n 1 n 2 V1~x b10,~xXadm
In view of that xn xˆn d n C2 n which proves (A.8).The last step is to prove
the inequality
0 x x x
T
for any x X . (A.10)
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n
n
T
xn x xn
1
n
2
V1 xn b1 un xn x
T
x
T
f xn n xn x xn .
n
(A.11)
and
x
x f x = x xˆ x f x
n x
T
n
n n
T
n
Since any polinomial function is Lipschitz continuos on any bounded compact set, we
can conclude that
x
f xn
x
f xˆ n Const xn xˆ n = O n
which gives xn xˆ
T
x
f xn O n which by (A.11) leads to
0 xn xˆn
T
x
T
T
f xn n xn x xn = O n n xn x xn
n n
(A.12)
n
Dividing both side of the inequality (A.12) by and in view (A.8) we finally obtain
n
0 O n xn x xn = o1 n xn x xn
T T
n (A.13)
This, by (13), for n leads to (A.10). Finally, for any x X it implies
T
0 x x x = x x x x x x x x
2
T
T
This inequality exactly represents the necessary and sufficient condition that the point
2
x is the minimum point of the function x on the set X . Obliviously, this point is
unique and has a minimal norm among all possible partial limits x .
Theorem is proven.
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REFERENCES
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