Supply Chain Strategies and International Tax Arbitrage

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.     

Procurement Contracts in the Presence of Endogenous Disruption Risk

We consider a manufacturer facing an unreliable supplier with high or low type on initial reliability. The private reliability can be enhanced through process improvement initiated by either manufacturer (manufacturer‐initiated improvement, MI) or supplier (supplier‐initiated improvement, SI). We derive optimal procurement contracts for both mechanisms and find that the moral hazard does not necessarily generate more profit for high‐type supplier. Furthermore, information asymmetry causes a greater possibility of not ordering from low type in SI than MI. For low type, when an upward effort distortion appears in both mechanisms, a decreased (increased) unit penalty should be imposed in MI (SI) compared with symmetric information case. Although possibly efficient effort from the supplier could yield greater channel profit in SI, several scenarios violate this expectation. However, the manufacturer's expected profit in MI is no less than that in SI. When MI is extended to MSI where both manufacturer and supplier can exert effort, the expected profits of two parties are equal to those in SI. We further extend SI to SID, where both process improvement and dual‐sourcing are available. The manufacturer considers the trade‐off between the benefit from diversification and the loss from dual information rent to decide to choose SID or MI. By comparing SID with pure dual‐sourcing, we find that supplier's process improvement could either accelerate or retard the exercise of dual‐sourcing.     

How Costs and Heterogeneous Consumer Price Sensitivity Interact with Add‐On Pricing

Firms often cite cost savings as a reason why they charge separately for add‐ons. Firms also often face situations where consumers' price sensitivity is correlated with their valuation of add‐ons. While cost savings may directly translate into profit gains in some scenarios, this study examines the strategic implications of add‐on pricing and is the first to suggest that cost savings from add‐on pricing may in fact result in profit loss for firms when consumers are heterogeneous in price sensitivity. This is because add‐on pricing can trigger a revenue loss that exceeds any cost savings, thus leading to a negative net profit change for competing firms. Even if firms have the capability to pre‐commit to not adopting add‐on pricing, we show that competing firms can be locked in a prisoner's dilemma where all choose to adopt add‐on pricing and lose profits (as compared to none adopting add‐on pricing). We further show the possibility that the greater the cost of providing the add‐on (and the greater the cost savings generated from add‐on pricing), the worse this profit loss gets.     

Role of Random Capacity Risk and the Retailer in Decentralized Supply Chains with Competing Suppliers

This research considers a supply chain under the following conditions: (i) two heterogeneous suppliers are in competition, (ii) supply capacity is random and pricing is endogenous, (iii) consumer demand, with and without an intermediate retailer, is price dependent. Specifically, we examine how uncertainty in supply capacity affects optimal ordering and pricing decisions, supplier and retailer profits, and the incentives to reduce such uncertainty. When two suppliers sell through a monopolistic retailer, supply uncertainty not only affects the retailer's diversification strategy for replenishment, but also changes the suppliers’ wholesale price competition and the incentive for reducing capacity uncertainty. In this dual‐sourcing model, we show that the benefit of reducing capacity uncertainty depends on the cost heterogeneity between the suppliers. In addition, we show that a supplier does not necessarily benefit from capacity variability reduction. We contrast this incentive misalignment with findings from the single‐supplier case and a supplier‐duopoly case where both suppliers sell directly to market without the monopolistic retailer. In the latter single‐supplier and duopoly cases, we prove that the unreliable supplier always benefits from reducing capacity variability. These results highlight the role of the retailer's diversification strategy in distorting a supplier's incentive for reducing capacity uncertainty under supplier price competition.     

考虑捐赠行为的食品动态定价策略研究

由于质量控制不当和库存过多导致的浪费是企业管理易腐食品面临的主要挑战。针对当前食品浪费严重的问题，建立考虑变质率的动态定价模型，研究捐赠行为下单一定价、两次定价与多级折扣定价三种定价策略对食品企业最优决策的影响。通过数值分析，发现捐赠行为能够提升企业利润且在多级折扣定价策略下效果更为显著，但当折扣次数较少时，单一定价策略对考虑捐赠的企业而言更优；食品最初质量、变质率、打折时间点、捐赠时间点、税收返回比率均是影响企业定价决策的重要因素；若质量差异越大，企业在多级折扣定价策略下的利润会减少，而考虑捐赠行为会使得企业利润呈上升趋势；在变质率越高时，考虑捐赠的单一定价策略会降低企业的利润，但对多级折扣定价策略下的利润影响不大；当折扣时间越接近于捐赠时间点时，基于捐赠行为的多级折扣定价策略会更优；当捐赠时间点越接近于保质期时，考虑捐赠的价格策略会优于不考虑捐赠时的价格策略。此外，研究还表明增加税收返回比率对考虑捐赠下的定价策略不一定是有利的。     

Sourcing from Multiple Suppliers for Price‐Dependent Demands

We analyze a model that integrates demand shaping via dynamic pricing and risk mitigation via supply diversification. The firm under consideration replenishes a certain product from a set of capacitated suppliers for a price‐dependent demand in each period. Under deterministic capacities, we derive a multilevel base stock list price policy and establish the optimality of cost‐based supplier selection, that is, ordering from a cheaper source before more expensive ones. With general random capacities, however, neither result holds. While it is optimal to price low for a high inventory level, the optimal order quantities are not monotone with respect to the inventory level. In general, a near reorder‐point policy should be followed. Specifically, there is a reorder point for each supplier such that no order is issued to him when the inventory level is above this point and a positive order is placed almost everywhere when the inventory level is below this point. Under this policy, it may be profitable to order exclusively from the most expensive source. We characterize conditions under which a strict reorder‐point policy and a cost‐based supplier‐selection criterion become optimal. Moreover, we quantify the benefit from dynamic pricing, as opposed to static pricing, and the benefit from multiple sourcing, as opposed to single sourcing. We show that these two strategies exhibit a substitutable relationship. Dynamic pricing is less effective under multiple sourcing than under single sourcing, and supplier diversification is less valuable with price adjustments than without. Under limited supply, dynamic pricing yields a robust, long‐term profit improvement. The value of supply diversification, in contrast, mainly comes from added capacities and is most significant in the short run.     

存在信息更新时的双源采购和后备生产结合策略研究

在现实的采购运作中,双源采购和后备生产是两种最常见的风险应对策略。本文在考虑信息更新的情况下,探讨了一个两阶段动态采购决策模型：第一阶段,制造商向存在供应风险的一个或两个主供应商订货;第二阶段,制造商根据主供应商风险信息的更新,决定是否向供应可靠但价格较高的后备供应商订货。本文得到了两阶段的最优采购策略,分析发现,当固定采购成本较低时：若潜在市场需求较小,双源采购将排斥后备生产;若潜在市场需求较大,双源采购和后备生产共存;若潜在市场需求适中,后备生产可能排斥双源采购,两者也可能共存。特别地,在潜在市场需求适中时,可靠性改进概率的增大或后备供应商生产成本的降低,将使后备生产趋于排斥双源采购;反之,可靠性改进概率的减小、固定采购成本的降低或后备生产成本的增加,将使两者趋于共存。     

Can formula apportionment really prevent multinational enterprises from profit shifting? The role of asset valuation,intragroup debt,and leases

The European Commission has been supporting a transition from a system of separate accounting to formula apportionment. After its 2011 draft directive was rejected by the Council, the Commission presented two new draft directives in October 2016, one stipulating rules for a common tax base and another the terms for consolidation and apportionment. The aspired system of unitary taxation is considered more resistant to profit shifting and assumed to reduce compliance costs. However, there are also doubts about the extent, to which such a system will eradicate tax-planning activities of MNEs. Other concerns have arisen about the practical issue of enforcing uniform rules for asset valuation throughout the member states. We use a dynamic model of tax accounting based on neoclassical investment theory and effective tax rates to determine to what extent formula apportionment mitigates the efficiency of typical profit-shifting strategies. We focus on the roles of transfer pricing and intragroup debt financing (through loans and leases) under both separate accounting and formula apportionment. We also take into account a possible leeway for inconsistent valuation. Our results show that instead of eliminating tax planning strategies, the proposed system might simply induce a shift from manipulating reported profits to influencing the apportionment key. Inside the European Union, the CCCTB may be able to render thin capitalisation rules and transfer pricing documentation redundant. However, formula apportionment invites for new forms of tax planning. It is therefore essential to give credit to these new kinds of tax incentives when implementing a system of unitary taxation.     

新兴智能回收下制造商转移定价决策

针对新兴智能回收,从闭环供应链渠道设计和回收定价角度,分别构建了单一回收渠道和双回收渠道下制造商一致和差异化转移定价决策模型,研究在制造商主导的闭环供应链中制造商的转移定价和最优利润决策问题。研究表明,相对于单一回收渠道,双回收渠道增加了产品回收率和供应链各成员利润;相对于差异化转移定价决策,制造商采取一致转移定价决策,能实现自身利润和智能回收商利润最大化,但会损害传统回收商利润,且不利于供应链其他成员利润的增长;当制造商采取差异化转移定价决策,虽不能实现自身利润最大,但相对于单一回收渠道,其利润也有所增长,也不会损害传统回收商利润,供应链其他成员的利润也会增长。     

Sourcing Decisions with Competitive Suppliers and Imperfect Information

Manufacturers often must choose between outsourcing and producing internally. This choice is complex and influenced by a variety of factors, including the costs and capabilities of the potential suppliers. In addition, if the manufacturer outsources, he must design the sourcing process. We study the manufacturer's outsourcing decision, with a focus on the impact of the sourcing process on that decision. We consider a setting in which the manufacturer has imperfect information regarding the suppliers' costs and capabilities, and we assume that the manufacturer uses a two‐stage sourcing process. The first stage is the qualification stage, in which the manufacturer seeks to reduce the uncertainty regarding the suppliers' capabilities. The second stage is the supplier selection stage, in which the manufacturer selects among the qualified suppliers on the basis of price. We first characterize the optimal design of the two‐stage process, and then consider the outsourcing decision. We demonstrate several trade‐offs. Vertical integration enables the manufacturer to reduce uncertainty and extract all of the profits of production. However, outsourcing enables the manufacturer to take advantage of the (potentially) lower costs and higher capabilities of the suppliers, particularly if competition between suppliers can be encouraged. We find that the manufacturer is more likely to vertically integrate when the warranty cost and the cost of exerting effort during qualification are large, and when there is significant uncertainty regarding the suppliers' capabilities. The manufacturer is more likely to outsource when the suppliers' costs (capabilities) are low (high), and when the number of suppliers is large.     

Strategic Sourcing in the Presence of Uncertain Supply and Retail Competition

This study develops an analytical model to evaluate competing retail firms' sourcing strategies in the presence of supply uncertainty. We consider a common supplier that sells its uncertain supply to two downstream retail firms engaging in price competition in a horizontally differentiated product market. The focal firm has a dual‐sourcing option, while the rival firm can only source from the common supplier. We assess the system‐wide effects of supply uncertainty on the focal firm's incentive to pursue the dual‐sourcing strategy. We find that the focal firm's dual‐sourcing strategy can create a win–win situation that leads to increased retail prices and expected profits for both firms. Furthermore, under certain conditions, we show that it is beneficial for the focal firm to strategically source from the common supplier, even if its alternative supplier offers a lower wholesale price. Overall, we identify two types of incentives for adopting the dual‐sourcing strategy: the incentive of mitigating supply risk through supplier diversification and the incentive of strategic sourcing for more effective retail competition.     

Price and Service Competition in an Outsourced Supply Chain

We consider a buyer who outsources the manufacturing of a product to multiple symmetric make‐to‐stock suppliers who compete on price and service (fill rate). The buyer allocates demand to the suppliers using a score function with an exponential form, which specifies the relative importance of price vs. service, in order to minimize his costs, while the suppliers choose their prices and fill rates to maximize their profits. For the case of dual‐sourcing, we characterize the optimal parameter of the exponential score function, considering the impact of the buyer's decisions on the suppliers, and considering how the suppliers compete against each other to earn a portion of the buyer's demand. We prove the existence of a unique equilibrium and characterize the equilibrium behavior of the system. We then consider a general number of suppliers and show that the equilibrium prices and fill rates, and the buyer's cost, are increasing in the number of suppliers. We compare these results to a model of single‐sourcing, in which the buyer is the Stackelberg leader and extracts all profits from the supplier. We find that the buyer always prefers single‐sourcing to multisourcing. Finally, we study a centralized system and use the results to develop a coordinating contract for the decentralized system.     

Pricing Policy in a Supply Chain: Negotiation or Posted Pricing

This article examines the choice of pricing policy (posted pricing or negotiation) toward end customers in a supply chain. Many retailers actively decide whether or not to encourage negotiation on the shop floor. Of course, the retailer's pricing policy influences not only the retailer's profit, but also the profits of the manufacturers who sell through the retailer. However, little is known about the forces that shape the pricing policy when two self‐interested parties interact in a supply chain. We consider two alternative models depending on who has the power to decide the pricing policy: the manufacturer or the retailer. We find that an increase in the wholesale price weakens the retailer's ability to price discriminate through negotiation. Therefore, the retailer prefers negotiation at lower wholesale prices and posted pricing at higher wholesale prices. We also find that whenever the retailer prefers negotiation, the manufacturer does too. Therefore, the retailer's discretion over the pricing policy causes friction only when the retailer wants to use posted pricing, while the manufacturer wishes the retailer to use negotiation. We show that such friction arises only when product availability or the cost of negotiation is moderate. In this case, we show that the manufacturer may offer a substantial discount to persuade the retailer to negotiate. Surprisingly, in this region of friction, a decrease in the supply chain's capacity or an increase in negotiation costs (both of which are typically considered as worsening the retailer's business environment) translates into higher profit for the retailer.     

Supply Chain Sourcing Under Asymmetric Information

We study a supply chain with two suppliers competing over a contract to supply components to a manufacturer. One of the suppliers is a big company for whom the manufacturer's business constitutes a small part of his business. The other supplier is a small company for whom the manufacturer's business constitutes a large portion of his business. We analyze the problem from the perspective of the big supplier and address the following questions: What is the optimal contracting strategy that the big supplier should follow? How does the information about the small supplier's production cost affect the profits and contracting decision? How does the existence of the small supplier affect profits? By studying various information scenarios regarding the small supplier's and the manufacturer's production cost, we show, for example, that the big supplier benefits when the small supplier keeps its production cost private. We quantify the value of information for the big supplier and the manufacturer. We also quantify the cost (value) of the alternative‐sourcing option for the big supplier (the manufacturer). We determine when an alternative‐sourcing option has more impact on profits than information. We conclude with extensions and numerical examples to shed light on how system parameters affect this supply chain.     

Retailer's Response to Alternate Manufacturer's Incentives Under a Single‐Period,Price‐Dependent,Stochastic‐Demand Framework*

This article considers the joint development of the optimal pricing and ordering policies of a profit‐maximizing retailer, faced with (i) a manufacturer trade incentive in the form of a price discount for itself or a rebate directly to the end customer; (ii) a stochastic consumer demand dependent upon the magnitude of the selling price and of the trade incentive, that is contrasted with a riskless demand, which is the expected value of the stochastic demand; and (iii) a single‐period newsvendor‐type framework. Additional analysis includes the development of equal profit policies in either form of trade incentive, an assessment of the conditions under which a one‐dollar discount is more profitable than a one‐dollar rebate, and an evaluation of the impact upon the retailer‐expected profits of changes in either incentive or in the degree of demand uncertainty. A numerical example highlights the main features of the model. The analytical and numerical results clearly show that, as compared to the results for the riskless demand, dealing with uncertainty through a stochastic demand leads to (i) (lower) higher retail prices if additive (multiplicative) error, (ii) lower (higher) pass throughs if additive (multiplicative) error, (iii) higher claw backs in both error structures wherever applicable, and (iv) higher rebates to achieve equivalent profits in both error structures.     

考虑顾客偏好的双渠道闭环供应链定价与协调决策

在双渠道闭环供应链背景下,基于消费者对传统零售渠道和网络直销渠道需求偏好的不一致,考虑渠道之间的竞争,研究了双渠道闭环供应链的定价及协调决策。首先,在分散化决策模式下分别建立了制造商领导的Stackelberg博弈、制造商和零售商Bertrand竞争博弈模型,得到了不同决策模式下的均衡解,并分析了消费者偏好程度、再制造成本节约等参数对节点企业定价决策和利润的影响。然后,以集中化决策下的均衡结果为基准,运用一种简单的价格机制和利润分享机制相联合实现了双渠道闭环供应链的完美协调。最后,通过数值模拟仿真分析了消费者偏好系数对节点企业利润及渠道总利润的影响。     

Technical Note – Pricing Below Cost Under Exchange‐Rate Risk

Pricing below cost is often classified as “dumping” in international trade and as “predatory pricing” in local markets. It is legally prohibited from practice because of earlier findings that it leads to predatory behavior by either eliminating competition or stealing market share. This study shows that a stochastic exchange rate can create incentives for a profit‐minded monopoly firm to set price below marginal cost. Our result departs from earlier findings because the optimal pricing decision is based on a rational behavior that does not exhibit any malicious intent against the competition to be considered as violating anti‐trust laws. The finding is a robust result, because our analysis demonstrates that this behavior occurs under various settings such as when the firm (i) is risk‐averse, (ii) can postpone prices until after exchange rates are realized, (iii) is capable of manufacturing in multiple countries, and (iv) operates under demand uncertainty in addition to the random exchange rate.     

On the Benefit of Inventory‐Based Dynamic Pricing Strategies

We study the optimal pricing and replenishment decisions in an inventory system with a price‐sensitive demand, focusing on the benefit of the inventory‐based dynamic pricing strategy. We find that demand variability impacts the benefit of dynamic pricing not only through the magnitude of the variability but also through its functional form (e.g., whether it is additive, multiplicative, or others). We provide an approach to quantify the profit improvement of dynamic pricing over static pricing without having to solve the dynamic pricing problem. We also demonstrate that dynamic pricing is most effective when it is jointly optimized with inventory replenishment decisions, and that its advantage can be mostly realized by using one or two price changes over a replenishment cycle.     

一体化下游企业的零部件自制与外包决策的供应链短期均衡研究

企业常常面临选择:零部件生产是自己制造还是外包给零部件供应商,在产业组织理论中是一个企业纵向一体化的选择问题。在分析指出下游企业零部件生产的外包和自制的市场行为改变了该产业组织的结构的基础上,本文分别以上游供应商利润、下游企业利润和消费者剩余为优化目标,研究上游供应商的产品定价、下游企业零部件生产的外包和自制决策,将cournot博弈嵌套到Stackelberg博弈中,建立该产业组织的复合博弈模型,得到了该产业组织在不同结构下的不同均衡,即相关企业的最优生产经营决策。对于上游供应商,下游企业零部件生产的外包比自制总是可以获得较高的利润,并且两者的差距随着市场容量的增加而增大,对于下游企业,其零部件自制获得的利润总是高于外包获得的利润,其竞争的下游企业的利润则也是与之同方向变化。这些结果可供供应链的企业在竞争环境下制定最优市场策略时参考,尤其是可供企业在零部件外包或自制决策时参考。     

Optimal Inventory Control with Dual‐Sourcing,Heterogeneous Ordering Costs and Order Size Constraints

We consider a dual‐sourcing inventory system, where procuring from one supplier involves a high variable cost but negligible fixed cost whereas procuring from the other supplier involves a low variable cost but high fixed cost, as well as an order size constraint. We show that the problem can be reduced to an equivalent single‐sourcing problem. However, the corresponding ordering cost is neither concave nor convex. Using the notion of quasi‐convexity, we partially characterize the structure of the optimal policy and show that it can be specified by multiple thresholds which determine when to order from each supplier and how much. In contrast to previous research, which does not consider order size constraints, we show that it is optimal to simultaneously source from both suppliers when the beginning inventory level is sufficiently low. We also show that the decision to source from the low‐cost supplier is not monotonic in the inventory level. Our results require that the variable costs satisfy a certain condition which guarantees quasi‐convexity. However, extensive numerical results suggest that our policy is almost always optimal when the condition is not satisfied. We also show how the results can be extended to systems with multiple capacitated suppliers.