Transfer Pricing in a Vertically Integrated Group
Altura Group has a mining division (Division M) that extracts a commodity and a processing division (Division P) that refines and sells it externally. Division M can sell all it produces on an external market at $410 per tonne; its variable cost is $230 and it has fixed costs of $18m on capacity of 200,000 tonnes. Division P buys 120,000 tonnes internally, currently at $410 (market price), refines at a variable cost of $95 per tonne and sells the refined product at $620. Division P's manager has found an external supplier at $370 per tonne and wants to buy externally, which would leave Division M with idle capacity. Division P earns a return on the group's invested capital; Division M is judged on divisional profit. The group's cost of capital is 12%. The group finance director is concerned that divisional optimisation is damaging group profit.
1. Analyse the group and divisional consequences of Division P sourcing externally at $370, and determine the correct transfer price range.
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Group perspective - internal transfer is better. Division M has spare capacity (it can produce 200,000t but only sells what it sells; the 120,000t to P can be replaced only at the market price). The relevant cost of internal transfer is Division M's variable cost, $230, not the market price, because the capacity is otherwise idle.
- Group cost of internal transfer = 230 + 95 = $325 per tonne.
- Group cost of external purchase = 370 + 95 = $465 per tonne.
- Group saving from internal transfer = $140 per tonne × 120,000 = $16.8m per year.
If P buys externally, Division M loses contribution of (410 − 230) × 120,000 = $21.6m, and the group pays $370 instead of incurring $230 - a real group loss of $16.8m.
Divisional perspective - the split is the problem. At a $410 transfer price, P's divisional profit on internal purchase = 620 − 410 − 95 = $115/t. Buying externally at $370 gives 620 − 370 − 95 = $155/t - a $40/t gain for P's manager, and a bonus. P's manager is behaving rationally under the current rule; the rule is wrong.
Correct transfer price range: the minimum is Division M's relevant (variable) cost, $230; the maximum is the external market price of the intermediate, $410 (above which P would rationally buy outside). Any price in [230, 410] leaves the group better off; the exact point is a negotiation over the $180/t of joint benefit, and the group should set it to share the gain fairly, e.g. $320.
2. Recommend how Altura should set transfer pricing policy and performance measures to align divisional and group interests.
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Policy:
- Two-part tariff or dual pricing. Charge P a price near variable cost ($230–$260) so P's decisions reflect true group economics, and credit M with a market-based price for its performance report, with the difference absorbed at group level. This removes the incentive to source externally while capacity is idle.
- Capacity-tiered rule. Where M has spare capacity, transfer at marginal cost plus a share of contribution; where M is at full capacity, transfer at market price ($410) because internal transfer then has a true opportunity cost. Make the rule explicit and pre-agreed so it is not renegotiated each year.
- Arms-length documentation for tax and regulatory compliance - the group must be able to justify the policy to tax authorities, so dual pricing must be carefully documented and may not be permissible in all jurisdictions; check before implementing.
Performance measures:
- Judge both divisions on group contribution or residual income from the integrated chain, not divisional profit alone. RI on the internal transfer at 12% cost of capital makes the $16.8m group gain visible to both managers.
- Remove the incentive for P to optimise its own purchase price at group expense by including a shared metric (e.g. group ROCE or integrated margin) in both managers' scorecards.
- Require capital and sourcing decisions above a threshold to be reviewed at group level on group cash-flow grounds.
Governance: a transfer pricing committee with a standing rule, plus periodic review of whether M's 'spare capacity' is genuinely spare - if external demand rises, the rule must switch to market price automatically.