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Supply Chain Strategies and International Tax Arbitrage

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  • Masha Shunko
  • Hung T. Do
  • Andy A. Tsay

Abstract

What motivates the geographic footprint of the supply chains that multinational firms (MNFs) deploy? Traditional research in the operations and supply chain management literature tends to recommend locations primarily based on differentials in production costs and the ramifications of physical distance ignoring the role of taxation. MNFs that strategically position parts of their supply chains in low‐tax locations can allocate the profits across the divisions to improve post‐tax profits. For the profit allocation to be defensible to tax authorities, the divisional operations must possess real decision authority and bear meaningful risks. Generally speaking, the greater the transfer of risk and control, the larger the allowable allocation of profit. These transfers may also create inefficiencies due to misalignment of business goals and attitudes toward risk. We model these trade‐offs in the context of placing in a low‐tax region a subsidiary that oversees product distribution (as a limited risk distributor commissionnaire, limited risk distributor, or fully fledged distributor). Our analysis demonstrates that the MNF's preferences regarding the operating structures are not necessarily an obvious ordering based on the amount of risk and decision authority transferred to the division in the low‐tax jurisdiction. We derive and analyze threshold values of the performance parameters that describe the main trade‐offs involved in selecting an operating structure. We find some of the optimal decisions to exhibit interesting non‐monotone behavior. For instance, profits can increase when the tax rate in the low‐tax jurisdiction increases. Numerical analysis shows that the Limited‐Risk Distributor structure is rarely optimal and quantifies when each alternative dominates it.

Suggested Citation

  • Masha Shunko & Hung T. Do & Andy A. Tsay, 2017. "Supply Chain Strategies and International Tax Arbitrage," Production and Operations Management, Production and Operations Management Society, vol. 26(2), pages 231-251, February.
  • Handle: RePEc:bla:popmgt:v:26:y:2017:i:2:p:231-251
    DOI: 10.1111/poms.12629
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    Cited by:

    1. Baozhuang Niu & Kanglin Chen & Lei Chen & Chao Ding & Xiaohang Yue, 2021. "Strategic Waiting for Disruption Forecasts in Cross‐Border E‐Commerce Operations," Production and Operations Management, Production and Operations Management Society, vol. 30(9), pages 2840-2857, September.
    2. Deng, Sijing & Xu, Jiayan & Han, Yonghui, 2023. "A proprietary component manufacturer’s global supply chain design: The impacts of tax and organizational structure," Omega, Elsevier, vol. 115(C).
    3. Guoming Lai & Yixuan Liu & Wenqiang Xiao, 2021. "International Taxation and Production Outsourcing," Production and Operations Management, Production and Operations Management Society, vol. 30(2), pages 402-418, February.
    4. Niu, Baozhuang & Li, Qiyang & Liu, Yaoqi, 2020. "Conflict management in a multinational firm's production shifting decisions," International Journal of Production Economics, Elsevier, vol. 230(C).
    5. Huang, Hongfu & He, Yong & Li, Dong & Li, Shanshan, 2023. "Competing multinationals’ backshoring decisions: Tax arbitrage versus production reliability tradeoff," European Journal of Operational Research, Elsevier, vol. 311(2), pages 515-532.
    6. Kim, Bosung & Park, Kun Soo & Jung, Se-Youn & Park, Sang Hun, 2018. "Offshoring and outsourcing in a global supply chain: Impact of the arm’s length regulation on transfer pricing," European Journal of Operational Research, Elsevier, vol. 266(1), pages 88-98.
    7. Huang, Hongfu & He, Yong & Chen, Jing, 2019. "Competitive strategies and quality to counter parallel importation in global market," Omega, Elsevier, vol. 86(C), pages 173-197.
    8. Lin, Zhiping & Shi, Ruixia & Stecke, Kathryn E. & Xiao, Wenli & Xu, Di, 2021. "Selling to a financially constrained E-commerce retailer with bankruptcy cost and tax," Transportation Research Part E: Logistics and Transportation Review, Elsevier, vol. 146(C).
    9. Lu, Xiangyuan & Wu, Zhiqiao, 2020. "How taxes impact bank and trade financing for Multinational Firms," European Journal of Operational Research, Elsevier, vol. 286(1), pages 218-232.
    10. Niu, Baozhuang & Mu, Zihao & Cao, Bin & Gao, Jie, 2021. "Should multinational firms implement blockchain to provide quality verification?," Transportation Research Part E: Logistics and Transportation Review, Elsevier, vol. 145(C).
    11. Yang, Huixiao & Ou, Jinwen & Chen, Xiaofeng, 2021. "Impact of tariffs and production cost on a multinational firm's incentive for backshoring under competition," Omega, Elsevier, vol. 105(C).
    12. Niu, Baozhuang & Yu, Xinhu & Dong, Jian, 2023. "Could AI livestream perform better than KOL in cross-border operations?," Transportation Research Part E: Logistics and Transportation Review, Elsevier, vol. 174(C).
    13. Niu, Baozhuang & Zhang, Nan & Xu, Haotao & Chen, Lei & Ji, Ping, 2022. "Inviting MNFs’ green offshoring: Is it an effective way to coordinate economic and environmental sustainability?," International Journal of Production Economics, Elsevier, vol. 254(C).
    14. Kopel, Michael & Löffler, Clemens, 2023. "Tax differences and international location strategies," International Journal of Production Economics, Elsevier, vol. 256(C).
    15. Baozhuang Niu & Zhipeng Dai & Lei Chen, 2022. "Information leakage in a cross-border logistics supply chain considering demand uncertainty and signal inference," Annals of Operations Research, Springer, vol. 309(2), pages 785-816, February.
    16. Wu, Zhiqiao & Lu, Xiangyuan, 2018. "The effect of transfer pricing strategies on optimal control policies for a tax-efficient supply chain," Omega, Elsevier, vol. 80(C), pages 209-219.
    17. Bernard Hoekman & Dominique Njinkeu, 2017. "Integrating Africa: Some Trade Policy Research Priorities and Challenges," RSCAS Working Papers 2017/43, European University Institute.
    18. Niu, Baozhuang & Shen, Zifan & Xie, Fengfeng & Liu, Yaoqi & Xu, Xin, 2022. "Real-time payment in cross-border operations considering local competition and tax-planning," International Journal of Production Economics, Elsevier, vol. 245(C).
    19. Niu, Baozhuang & Chen, Lingyun & Wang, Jingmai, 2022. "Ad valorem tariff vs. specific tariff: Quality-differentiated e-tailers’ profitability and social welfare in cross-border e-commerce," Omega, Elsevier, vol. 108(C).
    20. Niu, Baozhuang & Xu, Jingwen & Lee, Carman K.M. & Chen, Lei, 2019. "Order timing and tax planning when selling to a rival in a low-tax emerging market," Transportation Research Part E: Logistics and Transportation Review, Elsevier, vol. 123(C), pages 165-179.

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