The British Accounting Review xxx (xxxx) xxx

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The British Accounting Review

journal homepage: www.elsevier.com/locate/bar

The impacts of inventory in transfer pricing and net income:

Differences between traditional accounting and throughput
accounting
Gustavo da Silva Stefano*, Tiago dos Santos Antunes, Daniel Pacheco Lacerda,
Maria Isabel Wolf Motta Morandi, Fabio Sartori Piran*
~o Leopoldo, Brazil
Research Group on Modeling for Learning e GMAP | UNISINOS, Universidade do Vale do Rio dos Sinos e UNISINOS, Sa

a r t i c l e i n f o a b s t r a c t

Article history: This research proposes the Theory of Constraints (TOC) throughput accounting (TA) as an
Received 21 November 2019 alternative management control mechanism in an international transfer pricing setting.
Received in revised form 26 March 2021 We compare TA with the traditional accounting method and demonstrate that the tradi-
Accepted 31 March 2021
tional method underestimate factors as demand variation and inventories, which affects
Available online xxx
decisions, such as moving production to an offshore plant. A detailed system dynamics
model is built to simulate the production process in an offshore supply chain to compare
Keywords:
the methods. The study aims to fill a gap in the management accounting studies and
Transfer pricing
Theory of constraints
contribute to the understanding of international transfer pricing and their management
International supply chain controls, exploring more than just the tax savings, which are usually considered isolated
Offshoring from operational factors for supply chain (SC) offshoring decisions. Furthermore, we
conduct a brief literature review, present the model and discuss the results. It has been
observed that inventory levels are an important part of accounting, offshored supply
chains, and transfer pricing. Traditional cost and accounting methods favour higher in-
ventory levels, and they can overestimate net income results up to 70% e especially in
higher demand variation scenarios e when compared to the throughput accounting.
© 2021 British Accounting Association. Published by Elsevier Ltd. All rights reserved.

1. Introduction

Multinational supply chains make use of offshoring for cost-reducing reasons like tax avoidance (Joseph et al., 2017) and
cutting operational costs (Drtina & Correa, 2011). Consequently, the transfer of goods within these supply chains has become a
topic of interest. Accordingly, multinational enterprises (MNEs) utilize the transfer price to sell goods from one Supply Chain
Unit to another in the same company. Thus, transfer prices can be defined as the pricing of intercompany transactions that
occurs within its own subsidiaries (Feinschreiber, 2004).
Although widely discussed, transfer pricing has become a concern for multinational companies. In a report from Ernst &
Young (2016), p. 75% of the companies studied claimed that their major priority about transfer pricing was related to tax risk
management, while 72% assumed that transfer pricing has been a core focus of controversy within organisations. This

* Corresponding authors. Production and Systems Engineering Graduate Program, Universidade do Vale do Rio dos Sinos, 950, Unisinos Avenue, 93022-
~o Leopoldo, RS, Brazil.
750, Sa
E-mail addresses: gustavo.stefano.20@ucl.ac.uk (G. da Silva Stefano), fabiosartoripiran@gmail.com (F.S. Piran).

https://doi.org/10.1016/j.bar.2021.101001
0890-8389/© 2021 British Accounting Association. Published by Elsevier Ltd. All rights reserved.

Please cite this article as: G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al., The impacts of inventory in transfer pricing and net
income: Differences between traditional accounting and throughput accounting, The British Accounting Review, https://doi.org/
10.1016/j.bar.2021.101001
G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

controversy might be related to the fact that companies still consider isolated benefits, commonly only tax avoidance or
production and operational costs (Joseph et al., 2017), demonstrating a gap in accounting and supply chain management
perspectives as stated by Ramos (2004). This gap is concerning, since building a strong foundation of sound accounting
techniques is key for supply chain collaboration (Vann, 2016). To Borkowski (2002) transfer prices present challenges related
to tax compliance, supply chain management, and the location of manufacturing facilities, i.e. offshoring. More specifically,
there is still a gap between international tax objectives and the operational decisions of management control in MNEs, as
noted in studies such as the ones by Baldenius et al. (2004), Hyde and Choe (2005), and Narayanan and Smith (2000).
Tax optimisation motives and the usage of generally accepted accounting principles (GAAP) e absorption or full costing
methods e are often considered unfavourable for the optimisation of operational aspects regarding transfer prices such as
sourcing, pricing, and inventory decisions. In those scenarios, the utilisation of variable costing methods can provide better
guidance to managers and are seen as a valid option for management control (Eccles & White, 1988; Horngren et al., 2004).
Management accounting and control studies, however, have given little attention to transfer pricing in international settings
(Cools & Slagmulder, 2009). From this perspective, concerned with the negative impact of inventory reduction demonstrated
in GAAP, the Theory of Constraints (TOC) proposes the throughput accounting (TA) as an alternative (Budd, 2010; Hilmola & Li,
2016). In TA, throughput is defined as revenue minus all the variable costs e i.e. manufacturing, general, selling and
administrative (Brignall, 1997; Budd, 2010). TA can be similar to variable costing, following the same concepts of it, but
differing in that it can recognise labour as a fixed cost (Boyd & Cox, 2002; Budd, 2010). Since transfer pricing occurs in in-
ternational transactions where longer delivery times are expected, and, consequently, higher inventory levels occur, a
comparative study between the GAAP and throughput accounting concerning the impacts of transfer pricing in offshore
supply chains is important. However, as pointed out by Budd (2013), there is a lack of TOC literature in accounting and finance.
So far, the TOC literature has considered only local or domestic transfer prices (Ronen & Pass, 2008). An analysis considering
the international transfer price setting, as proposed in this paper, has not been identified in the TOC literature as well.
In a broader sense, with an accounting perspective in a supply chain context, the relationship between these two topics is
also explored. More specifically, this work aims to fill the gap in management accounting and control studies proposing
throughout accounting as an alternative and demonstrating the importance of inventory considerations in an international
transfer pricing (TP) setting. We demonstrate that by conducting a preliminary comparative study of the GAAP and
throughput accounting, which could lead to better understanding of the impacts of offshoring operations and international
transfer pricing on supply chains, based on the TOC perspective. Therefore, we analyse the importance of inventory levels in a
transfer pricing setting and the impacts on the Net Income After Tax using and comparing GAAP and throughput accounting.
To do so, a basic transfer pricing example was created, and a sensitivity analysis was conducted through simulation in a
system dynamics model. We demonstrate with our analysis that inventories affect the optimal transfer price, that the
traditional cost and accounting methods favour higher inventory levels and that it can overestimate net income results e
especially in higher demand variation scenarios e when compared to the throughput accounting.
The main contribution of the paper is to demonstrate that TA can be used as an alternative to GAAP accounting for
management accounting and control, addressing serious disadvantages and concerns presented in absorption costing (GAAP)
methods. Thus, we show that it can support supply chain decision-making regarding the offshoring of operations and that
inventory levels play an important role in such settings. As, in those scenarios, the suggested usual performance metric is
profit and/or return on investment of company divisions (Smolarski et al., 2019), the traditional accounting method can be
misleading to managers, as they tend to overestimate profits based on inventory levels. The throughput accounting tries, in
this case, to diminish this problem by being more restrictive regarding the gains derived from inventories, as it accounts only
variable costs in its value.
The remainder of this paper is structured as follows: the next section provides a brief literature review on throughput
accounting and transfer pricing. Section 3 covers the research methodology. Section 4 presents the model. Section 5 presents
the results and the discussion, and Section 6 concludes the study.

2. Literature review

This section aims to provide a basic understanding of the concepts used in our research. We will first present the sys-
tematic literature review (SLR) conducted for our study, which is followed by the background literature on throughput ac-
counting and on the relevant transfer pricing problems.
The systematic literature review search was conducted in the Scopus and Web of Science (WOS) databases using the
defined keywords and search terms shown in Appendix A and delimited by publications from the last ten years. As no relevant
important papers were found in 2020, we decided to set the time frame from 2009 to 2019. We also limited our search by the
relevant important subjects, documents written in English and considered only articles or proceedings papers. This initial
search resulted in 205 documents, and, by excluding the duplicates, 156 documents remained. All of these had their titles and
abstracts analysed, and only 28 papers were selected for the final analysis. After the complete reading of these, 3 of them were
removed for not being relevant, which resulted in 25 papers for the literature review. Additionally, we also searched the
British Accounting Review database and found 13 documents. However, from the analysis of their titles and abstracts, none of
these documents were found to be relevant to offshoring scenarios or the international transfer pricing setting.
From the documents analysed, two streams of journals were found. One of them was more related to SCM e mixing
operations research (OR) and operations management (OM) e and the other was more linked to accounting. The publications

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

seemed to be spread among different journals, as, out of the 25 documents and 19 different journals, only 4 journals had 2 or
more publications, as can be seen in Table 1.
The journals were also classified in their most related research stream, these being either accounting or SCM and oper-
ations (OM/OR). From Table 1, for example, the first two journals were classified as SCM and operations, while the next two
were classified as accounting. A total of 9 documents were related to accounting journals, while the remaining 16 were related
to supply chain and operations. It is possible to note that a significant part (36%) of the publications come from accounting
research, whereas most publications (64%) are related to operations management and operational research.
Most of the literature, both in accounting and SCM, consider inventories as just a variable in a complex system and not a
key aspect of it, such as seen in Rossing et al. (2017) and Perron et al. (2010). In the SCM literature, inventory in global
offshored supply chains has received more attention. Seppa €la
€ et al. (2014) demonstrate through a case-study that a company
division in one country is more profitable than the others due to its domestic production and thus smaller inventory and
shipping costs. Similarly, Stentoft et al. (2018) mentioned high inventory levels as a decisive motivation for backshoring e the
reverse strategy of offshoring, i.e. moving back to the domestic country. Blackburn (2012), however, demonstrates that
inventory-related costs are insensitive to the increased lead-time derived from offshoring when measured as a percentage of
unit cost.
Although accounting research has not given proper attention to inventories in a global supply chain setting with inter-
national transfer pricing, it has received attention in other cases. Pong and Mitchell (2006) found that inventories are a key
aspect in profit measurement, and that some companies in the UK could have their reported profitability changed drastically,
depending on the method used for inventory valuation. Comparing full cost and variable costing, the authors suggest more
studies exploring such comparisons. More recently, the authors found that inventory control improvement became an
operational focus of managers, and, consequently, inventory days have been decreasing over time (Pong & Mitchell, 2012).
Thus, we show through a simple model that these inventories can have a huge impact on the profits of a global supply chain.
We continue by providing a brief literature background on throughput accounting and transfer pricing.

2.1. Throughput accounting

The Theory of Constraints (TOC) was defined by its founder as a general approach to managing an organization (Goldratt,
1988). In the TOC, three paradigms are used as its primary guiding principles: logistics, global performance measures and the
thinking process (Tulasi & Rao, 2012). The context of global performance measures is where we identify the Throughput
Accounting (TA). According to Tulasi and Rao (2012), as the goal of an organization is to make money now and in the future,
unlike traditional accounting, the TOC global performance measures propose a set of indicators to focus on achieving the goal.
The throughput accounting method originated in the 1990s, and was improved as a managerial decision-making tool by
Goldratt (Hilmola & Gupta, 2015; Ronen & Pass, 2008; Sulaiman & Mitchell, 2005). The focus of throughput accounting is how
to use the capacity constraint to generate, as much as possible, throughput dollars (Bragg, 2011). The TOC pursues three basic
goals: increased throughput, decreased inventory and decreased operating expenses. Compared to the generally accepted
accounting principles (GAAP), throughput accounting reflects the same behaviour regarding increases in throughput
(contribution margin in GAAP) and decreases in operating expenses (fixed costs in GAAP). Inventory decreases, however,
reflect unfavourable figures on GAAP statements due to reductions in assets and operating income (Budd, 2010). Table 2
exemplifies and compares GAAP and the throughput accounting statements.
Basically, throughput can be defined as revenue minus all the variable costs e i.e. manufacturing, general, selling and
administrative (Brignall, 1997; Budd, 2010). Noreen et al. (1995) stated that, if necessary, in order to simplify the throughput
accounting, only direct material should be considered as variable costs. The authors claimed that the assumption is coherent,
as most of the labour time, for instance, cannot be considered variable, since wages are not related to units produced or sold,
and adjustments or cuts in the workforce cannot be directly related to production or sales levels. In the example demon-
strated in Table 2, labour is considered as fixed cost, whereas other than direct material some manufacturing overhead is
identified as variable as well. Corbett (1999) claimed that the TA is a more modern method than traditional accounting to
assess throughput, direct labour and overheads. Dugdale and Jones (1998), however, stated that TA techniques had already
been presented in previous accounting theory and that its contribution lies in the call for change of the accounting mindset.
Nevertheless, the main distinctions between TA and GAAP are: throughput in GAAP is the total production of a company,
while in TA it is the rate at which the system generates money through sales; in TA fixed costs should not be allocated to
product units; direct labour is a variable expense in GAAP, while in TA it is a fixed cost, at least in the short and medium terms;
traditionally, inventory is treated as an asset and finished and unfinished goods increase its value, in TA and TOC though they

Table 1
SLR results by Journal. Prepared by the authors.

Journal Documents
European Journal of Operational Research (EJOR) 4
International Journal of Production Economics (IJPE) 2
Management Accounting Research (MAR) 2
Journal of Accounting and Organizational Change (JAOC) 2
Other journals 15

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

Table 2
Traditional and throughput accounting comparison. Adapted from Budd (2013).

Traditional Income Statement

Revenues (15,000 units @ $ 20) $300,000
Cost of goods sold
Beginning finished goods $0
Direct materials used ($40,000)
Direct labour (all variable) ($25,000)
Variable mfg. overhead ($20,000)
Fixed mfg. overhead ($80,000)
Total cost of goods mfgd. ($165,000)
Ending finished goodsa $41,250
Total cost of goods sold ($123,750)
Gross margin $176,250
Selling and administrative expenses ($105,000)
Variable ($30,000)
Fixed ($75,000)

Net operating income $71,250

Throughput Income Statement

Revenues (15,000 units @ $ 20) $300,000
Variable costs
Beginning finished goods $0
Direct materials ($40,000)
Variable mfg. overhead ($20,000)
Var. cost of goods mfgd. ($60,000)
Ending finished goodsb $15,000
Sum of var. costs and goods ($45,000)
Variable sell. and admin. ($30,000)
Total variable costs ($75,000)
Throughput $225,000
Fixed costs
Manufacturing ($80,000)
Labour ($25,000)
Selling and admin. ($75,000)
Total fixed costs ($180,000)
Net operating income $45,000
a
5000 units @ $ 8.25 (variable and fixed manufacturing costs).
b
5000 units @ $ 3.00 (only variable manufacturing costs).

are regarded as raw-material and not all the processing costs are accounted for work-in-progress or goods (Corbett, 1999;
Naor et al., 2013). In this sense, in TA as inventory costs do not carry fixed costs as GAAP does, inventory values are smaller,
reducing the benefits of holding inventory, as can be seen in Table 2.
With regards to the application of TA with TP, Ronen and Pass (2008) proposed a structured methodology based on the
throughput accounting, the global decision-making (GDM). The GDM is composed of three steps: 1) Make a global economic
decision based on the CEO perspective; 2) Consider strategic factors; and 3) Change local performance measures. The
throughput accounting is used in the first step, and, according to the authors, such a decision should achieve an optimal
contribution to the organization’s objective and reflect the expectations of the CEO. The utilisation of TA should allow a
company to make optimal choices globally instead of locally. They cited a brief example of a company that had the option of
purchasing a service for a project from their own company or from a supplier at a lower price. In such a case, most project
managers would prefer the local optimal decision of buying at the lower price, even though it leads to a loss for the orga-
nisation. Then, the authors affirmed that the GDM methodology can be helpful in pricing decisions, definition of bid prices,
and determination of transfer prices. However, the example given is brief and used in a simple domestic transfer price sit-
uation. To the best knowledge of the authors, no work has made use of TA and a complete, detailed assessment in an in-
ternational TP setting.
According to Jones and Dugdale (1998), TOC and the TA provides a coherent, comprehensive and articulated solution to
substitute traditional management approaches. Throughput accounting offers a different vision suitable for a manufacturing
environment that requires a paradigm change for accounting and accountants, focusing and reinforcing attention (Corbett,
1999; Dugdale & Jones, 1998). Although throughput accounting has received attention in accounting research (Gupta &
Boyd, 2008), more recently, it has received less publications (Hilmola & Gupta, 2015), leaving a gap in the research on the
theme.

2.2. Transfer pricing for management control

Gao and Zhao (2015) defined transfer pricing as the pricing of an intermediate good or service that is transferred between
divisions of the same multinational company. Transfer pricing is a complex subject, as many variables impact and are

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

impacted by decisions related to it; to cite a few: centralisation or decentralisation of supply chain decision-making (Wang
et al., 2016); uncertainty of demand (Zhang et al., 2016); logistics and transportation costs (Miller & De Maria, 2008; Vidal &
Goetschalckx, 2001); the defined transfer pricing methodology (Huh & Park, 2013); inventory holding (Susarla & Karimi,
2012); production capacity (Hasani et al., 2014); the arm’s length principle (Matsui, 2011); among many others.
Transfer prices are a key strategic aspect of determining the location of manufacturing or shared service facilities for MNEs
(Borkowski, 2002; Kim et al., 2018). MNEs can set their transfer prices strategically to increase results, determining how the
income of the agents is divided among the countries for income tax purposes (Lo € ffler, 2019). In this sense, tax authorities set
rules on transfer pricing methods to control tax avoidance and ensure compliance (Rossing, 2013). However, the TP concepts
related to the tax compliance issue cannot be separated from its managerial and economic aspects (Baldenius et al., 2004;
Hyde & Choe, 2005), as they also affect the incentives of their divisions, based on their own performance (Cools et al., 2008).
Thus, TP decisions increase in complexity if they need to consider both taxation compliance and management control di-
mensions (Lo € ffler, 2019).
Although transfer prices are regulated by governments following the arm’s length principle defined by the Organisation
for Economic Co-operation and Development (OECD) (Hammami & Frein, 2014a), the transfer price can be optimised to
increase net profits through tax avoidance and reduce operational expenses (Joseph et al., 2017), and improve other per-
formance measures. The arm’s length principle provides guidance for the national tax authorities, providing proper taxation
among countries, but it is not necessarily applicable to managerial uses of TP. However, in reality, as found by Joseph et al.
(2017), companies usually do not calculate their tax savings versus the supply chain costs related to the tax strategy, and
most firms still focus on tax compliance issues (Klassen et al., 2017). Still, tax compliance has a great impact on the perfor-
mance of divisions and their management control systems (Cools et al., 2008; Cools & Slagmulder, 2009). Thus, in the model
that considers an international transfer pricing setting with the relevant taxes, we study how management control and tax
dimensions co-exist and affect the overall system by comparing both traditional accounting and the TA.
Being a complex matter, transfer pricing has generated many complex model variations to optimize supply chain profits.
These models vary according to the supply chain models and other variables, and use techniques like linear programming,
heuristics (De Matta & Miller, 2015; Goetschalckx et al., 2002) and game-theoretical approaches (Clempner & Poznyak, 2018;
Rosenthal, 2008). However, other studies have been conducted outside the profit optimisation problem. Kumar and Sosnoski
(2011) researched the SME environment, analysing the impacts of not complying with transfer price regulations, and of
proposing a decision framework to select the transfer pricing method; Matsui (2011) studied the impact of arm’s length
regulation of consumer welfare in the trading countries, multinational firm profits and total world economic welfare; Joseph
et al. (2017) conducted an empirical research to collect evidence on how tax strategies may affect supply chain decision-
making and strategies. In a case study on global supply chains and TP, Seppa €la
€ et al. (2014) affirmed that managers are
well aware that inventory and logistics costs significantly impact the overall supply chain profitability. However, according to
the authors, generally those costs have been neglected or included in other residual costs.

3. Methodology

Bertrand and Fransoo (2002) mention two types of quantitative models: axiomatic and empirical. Empirical models focus
on fitting the model according to observations and reality, while axiomatic models aim to achieve solutions within a specific
model and ascertain that the solutions obtained give insights into the problem structure. Additionally, they also differentiate
normative and descriptive research. Normative research is concerned with developing policies, strategies and actions to
achieve better results than those found in the current literature; finding an optimal solution to a new problem or compar-
atively analysing different strategies based on a specific problem. Descriptive research, on the other hand, is concerned with
analysis of the model, seeking understanding and explanation of its characteristics. Therefore, we define our research as
axiomatic descriptive.
Bertrand and Fransoo (2002) affirmed that, in axiomatic descriptive research, the researcher uses a conceptual model e
usually taken from the literature e to conduct analyses that provide insights into the behaviour of this model. Therefore, the
authors proposed a research methodology that would guide this research, containing a conceptualisation of the problem,
creation of the model, the results, analysis of the results, and the insights generated by the model. Thus, the paper begins with
the definition of the problem, structured by a literature review already presented in the Introduction and the Literature
Review sections. In this section, we present the methodology applied, followed by an explanation on the System Dynamics
methodology. Next, the model is constructed using an example from the literature. Then the validation is conducted by
comparing the results of the model to the figures presented in the original example. The model construction, model solution
and validation are all detailed in the next section. Finally, we implement the proposed TA techniques for the result analysis by
conducting a descriptive analysis composed of multiple sensitivity analyses e which are fully described in Section 5. Having
defined the methodology used, in the next section, we continue the work by presenting the model construction.
Within the international setting of transfer prices, axiomatic research is commonly used in transfer price and accounting
studies. Empirical research proves difficult as the required data sensitive for organisations is scarce (Cools & Slagmulder,
2009). Examples of this can be found in Baldenius et al. (2004), Hyde and Cloe (Hyde & Choe, 2005), and Narayanan and
Smith (2000). Such research explores idealised models to generate knowledge about transfer prices, management control
systems and their impacts on the model and system in an exploratory way. Next, continuing the method explanation, the
System Dynamics technique is presented.

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

3.1. System dynamics

Created by Jay Forrester in the 1950s (Law, 2014), system dynamics is a set of tools and a simulation approach originally
designed to be used in the industrial sector (Mansilha et al., 2019; Pidd, 2003). Pidd (2003) defined two modes of operation in
the system dynamics (SD) approach. The basic one provides a way of visualising human systems by focusing on the
importance of some particular structural features, such as feedback control. Instead, the second operation mode uses the
same structural features as in the basic one to develop a computer-based simulation model of the systems, and uses quan-
titative data.
System dynamics tends to look at systems from a high-level view, and is used to take decisions that are more strategic
(Law, 2014; Martins et al., 2020). However, the (SD) modelling can be used for any dynamic system, at any time and on any
spatial scale (Sterman, 2000). According to Sterman (2000), SD is concerned with the behaviour of complex systems, and
requires more than just technical tools to create mathematical models. As Law (2014) specified, (SD) has three key compo-
nents; Fig. 1 presents a basic SD model and its components, which are described next:

a) Stock: defined as a resource accumulation, and is represented by a rectangle;

b) Flow: a stream of a specific resource that enters or leaves the inventory. It is represented by double-line arrows with a
valve in the middle;
c) Converter: used to represent parts at the boundary of the system, i.e. parts whose values are not determined by the
behaviour of the system itself. It is represented by a circle;
d) Information link: used to transfer information about an inventory or a variable to a flow. Here it is represented by a
curved arrow.

However, within the supply chain context, other techniques could be reasonable options too, such as Discrete-Event-
Simulation (DES), Agent-Based Simulation (ABS) or optimisation models. According to Sweetser (1999), DES is best suited
to providing detailed analysis of systems composed of linear processes, and is used when the goal is a statistically valid
estimation of system performance. Also, SD is best used when the problem is associated with a continuous process in which
feedback loops are frequent in the system and impact its own behaviour (Morecroft & Robinson, 2005; Sweetser, 1999; Tako &
Robinson, 2012). However, there is an overlap between these two techniques, and many problems could be modelled with
either approach and still present very similar results (Morecroft & Robinson, 2005; Sweetser, 1999). Agent-based modelling
simulates autonomous entities that act on behalf of real-world actors, dynamically supporting the decision-making process,
as well as taking into consideration knowledge of their own environments (Christos et al., 2016). In other words, the agent-
based approach models the complexity arising from individual actions and interactions that occur in the real world (Siebers
et al., 2010).
In turn, analytical approaches, such as optimisation or mathematical models, provide good results in supply chains that are
well-defined, possess few decision variables and restrictive assumptions (Chen & Paulraj, 2004). However, Ge et al. (2015)
claim that analytical representations of problems may not represent a realistic perspective in cases within complex dy-
namic systems. Chan and Chan (2010) suggest simulation instead of analytical models when the behaviour and the dynamics

Fig. 1. Basic SD model. Adapted from Law (2014).

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

of the supply chain are the focus. As there is no interest in individual actions and interactions within the proposed system,
and, given the exploratory nature of the research, which aims to understand the behaviour of the system through two
different accounting methods, the authors decided to use the SD approach.
Although SD is presented as a reasonable approach to simulate enterprise systems, the authors found no previous work
using this approach to deal with the aforementioned problem. Similarly, throughput accounting has only been applied to
domestic transfer price scenarios, and no studies were found dealing with international transfer prices. In the next section, we
aim to demonstrate the creation of an SD model.

4. Model presentation

This section covers the model construction, explaining its logic and detailing the sectors within it, followed by an
explanation of the process used to validate it.

4.1. Model construction

The authors found it difficult to find actual empirical data to create the model, mainly because these kinds of data are
strictly confidential for companies, as they concern pricing methodologies and tax information. We also acknowledge the TP
setting complexity (Cecchini et al., 2013; Smolarski et al., 2019), and thus we chose to take a simpler approach to the problem
using a more didactic model. Therefore, we derived data from the basic example provided by Vidal and Goetschalckx (2001).
In the example, the authors used a company comprising Unit A and Unit B to demonstrate a simple income statement and the
transfer pricing impacts on it. Unit A is located in a country with lower tax rates, and transfers materials to Unit B. They also
noted that the transfer price that maximised net profit after tax had an optimal value of around $12 per unit. We present this
example in Table 3.
In the example given, we included inventory. Logically, inventory levels may be higher in international supply chains when
compared with those in domestic supply chains. For that matter, we took the table above and added inventory levels to both
subsidiaries (Units) A and B, which is demonstrated in Table 4. Table 4 data also represents the initial data (DT ¼ 1.00) of the
model.

Table 3
Income statement with transfer prices. Adapted from Vidal and Goetschalckx (2001).

SubsidiaryA SubsidiaryB Group Total

Detail
Transfer price @ $11/unit, sales @ $20/unit and20,000 units sold
Sales 220.000 400,000 400,000
Variable costs (140,000) (140,000)
Procurement costs (220,000)
Import Duties (12%) (26,400) (26,400)
Fixed Costs (20,000) (120,000) (140,000)
Net Income Before Tax (NIBT) 60,000 33,600 93,600
Tax rate 34% 50%
Tax payable (20,400) (16,800) (37,200)
Net Income After Tax (NIAT) 39,600 16,800 56,400

Transfer price @ $12/unit, sales @ $20/unit and20,000 units sold

Sales 240,000 400,000 400,000
Variable costs (140,000) (140,000)
Procurement costs (240,000)
Import Duties (12%) (28,800) (28,800)
Fixed Costs (20,000) (120,000) (140,000)
Net Income Before Tax (NIBT) 80,000 11,200 91,200
Tax rate 34% 50%
Tax payable (27,200) (5,600) (32,800)
Net Income After Tax (NIAT) 52,800 5,600 58,400

Transfer price @ $13/unit, sales @ $20/unit and20,000 units sold

Sales 260,000 400,000 400,000
Variable costs (140,000) (140,000)
Procurement costs (260,000)
Import Duties (12%) (31,200) (31,200)
Fixed Costs 20,000 (120,000) (140,000)
Net Income Before Tax (NIBT) 100,000 (11,200) 88,800
Tax rate 34% 50%
Tax payable (34,000) - (34,000)
Net Income After Tax (NIAT) 66,000 (11,200) 54,800

7
G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

Table 4
Income statement with inventory levels. Prepared by the authors.

Transfer price @ $11/unit.3.000 units of inventory inA and2,000 units of inventory inB. 25,000 units produced in A and 22,000 units bought by B

SubsidiaryA SubsidiaryB Group Total

Sales 242,000 400,000 400,000
Variable costsa (175,000) (175,000)
Procurement costs (242,000)
Import Duties (12%) (29,040) (29,040)
Fixed Costs (20,000) (120,000) (140,000)
Total cost of goods mfgd (195,000) (391,040) (586,040)
Inventoryb 23,400c 35,549d 58,949
Cost of goods sold (171,600) (355,491) (527,091)
NIBT 70,400 44,509 114,909
Tax rate 34% 50% e
Tax payable (23,936) (22,255) (46,191)
NIAT 46,464 22,255 68,719
a
Variable cost of 7 $/unit * 25,000 units.
b
(Total cost of goods mfgd./units produced or bought) x units in inventory.
c
(195,000/25,000 units) x 3000 units ¼ 23,400.
d
(391,040/22,000 units) x 2000 units ¼ 35,549.

Fig. 2. Production sector of the model. Prepared by the authors.

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

For the model construction, we added safety stock levels to both Units A and B so that we could have units stocked in the
inventories from the beginning of the simulation. Also, we built our model simulation to run on a monthly time frame. In our
model, Unit A supplied Unit B once a month, according to the quantity ordered from Unit A. However, we considered a delay in
the flow of the units bought in order to simulate the time to produce and deliver the goods. The demand was directly linked to
sales, and was considered known, normally distributed with an average of 20,000 units, a standard deviation of 1000 units
and a starting value of 20,000 units. Safety stocks serving as protection were set at 3000 and 2000 units in Unit A and B,
respectively. The model was constructed in Stella version 9.0 software from Isee systems. The production sector of the model
is presented in Fig. 2.
From the production model, we derived the sectors for traditional accounting and throughput accounting. As our model
used a monthly time frame, we needed to “store” the net monthly incomes before tax (NIBT), so that, after 12 months, we
“paid” the proper taxes. Additionally, we used flows for both taxes and NIBT to keep track of them. This simulated a real
company where the taxes were provisioned to a specific account to be paid at the end of the fiscal year. We used flows to
determine actual values being accounted and variables to find specific metrics. Fig. 3 presents the traditional accounting
sector of the model.
The throughput accounting sector uses the same logic as the model above, although the net income after tax (NIAT) uses
the taxes paid from the traditional accounting sector, as governments regulate taxes through traditional income statements.
All the equations, formulas and starting values of the model are presented in Appendix A. Fig. 4 presents the throughput
accounting sector of the model.
After presenting the model, we conducted some validations to ensure that the proposed model worked as expected.

4.2. Model validation

To validate the model, we used a simple Excel spreadsheet, as demonstrated in Table 4. We ran the model with the initial
transfer price of $11/unit e just as proposed by Vidal and Goetschalckx (2001), and then we increased and decreased this
value to guarantee that the NIAT figures for both GAAP and throughput accounting were correct. The TP changes were to $2/
unit and $25/unit, respectively. Table 5 presents the throughput accounting values with TP $11/unit.

Fig. 3. Traditional accounting sector of the model. Prepared by the authors.

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

Fig. 4. Throughput accounting sector of the model. Prepared by the authors.

Table 5
Throughput accounting for model validation.

Transfer price @ $ 11/unit. 3,000 units of inventory in A and 2,000 units of inventory in B.

SubsidiaryA SubsidiaryB Group Total

Sales 242,000 400,000 400,000
Variable costs (175,000) (175,000)
Procurement costs (242,000)
Import Duties (12%) (29,040) (29,040)
Variable cost of goods mfgd (175,000) (271,040) (446,040)
Inventory 21,000 24,640 45,640
Variable costs of goods sold (154,000) (246,400) (400,400)
Throughput 88,000 153,600 241,600
Fixed Costs (20,000) (120,000) (140,000)
Net Operating Income 68,000 33,600 101,600
Tax payable (23,936) (22,255) (46,191)
NIAT 44,064 11,345 55,409

Then, to validate the model, we compared the values found on the spreadsheets and the ones found in the model. For
validation purposes only, the model was set to run from time 1 to 2, with DT (interval between calculations) as 1. For the
validation, we used the following flows: Monthly NIAT A, Monthly NIAT B, Monthly NIAT A TA, and Monthly NIAT B TA (Table
6). It was expected that any differences or errors of any other variables would be reflected in these four.
After this, we validated the NIBT inventories and the annual NIAT flow. Since we had planned to run the model in months,
we needed to simulate the model for at least 13 months. Since we were stocking NIBT and the simulation took 1 unit of time to
increase or decrease the inventories, the total yearly NIAT would be known only at the time of unit 13. This is considered as the
time taken by a company to close its financial year. It will know its yearly results in January e considering that the fiscal year
runs from January to December. The NIAT and tax paid flows are logically set to work only after every 12 months of simulation.
Therefore, it is important to note that the NIBT inventories start again only in the second month. In the 13th month of the

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

Table 6
Expected results and model results. Prepared by the authors.

Expected value (Excel) Model results

TP ($/unit) NIATA NIATB NIATA TA NIATB TA NIATA NIATB NIATA TA NIATB TA

2.00 127,600.00 123,054.55 130,000.00 112,145.45 127,600.00 123,054.55 130,000.00 112,145.45
11.00 46,464.00 22,254.55 44,064.00 11,345.45 46,464.00 22,254.55 44,064.00 11,345.45
25.00 249,744.00 269,090.91 247,344.00 280,000,00 249,744.00 269,090.91 247,344.00 280,000.00

Table 7
Timing validation example. Prepared by the authors.

Month Time Net income A NIBT A NIAT A Net income A TA NIBT A TA NIAT A TA
January 1 70,400 e e 68,000 e e
February 2 130,059 70,400 e 123,000 68,000 e
March 3 82,465 200,459 e 79,404 191,000 e
April 4 83,134 282,924 e 80,100 270,404 e
May 5 83,503 366,058 e 80,484 350,504 e
June 6 85,094 449,562 e 82,136 430,988 e
July 7 76,497 534,655 e 73,172 513,124 e
August 8 72,886 611,153 e 69,376 586,296 e
September 9 79,694 684,039 e 76,516 655,672 e
October 10 87,934 763,733 e 85,080 732,188 e
November 11 92,289 851,667 e 89,580 817,268 e
December 12 93,003 943,957 e 90,316 906,848 e
January 13 82,046 1,036,960 684,394 78,968 997,164 644,598
February 14 70,485 82,046 e 66,840 78,968 e
March 15 73,448 152,531 e 69,968 145,808 e

From the validation, we proceeded to conducting and demonstrating the results, covered in the next section.

simulation, the value will be the aggregate value of NIBT of the previous 12 months, in other words, the complete year. To
exemplify, Table 7 provides the figures from the simulation from time 1 to 15 with transfer prices returned to $11/unit. The
blue fields register the relation of the figures. The same validation was performed for Unit B.

5. Results and discussion

To make a full analytical comparison of the company, we added one more sector to the model. Basically, we used two
variables to report the aggregate net income after tax in Unit A and Unit B. Fig. 5 demonstrates these sectors.
We first made a simulation to see the results of the net income after tax with the inventory costs and compared the GAAP
accounting method and that of throughput accounting. To do so, we used the Stella sensitivity analysis functionality. We made
a scatter chart comparing the total net income after tax with the transfer price. Fig. 6 shows the comparison between the
GAAP on the left and the throughput accounting on the right. 8 sensitivity runs were performed with transfer prices ranging
from $11/unit (run 1) to $18/unit (run 8), with incremental increases set at $1/unit for each run. Each point of the figure
represents a different run.
It is possible to notice that the optimum transfer price changed. As seen in Table 3, the optimal price was around $12/unit
while, in our example, the inventories changed the optimal transfer price to approximately $14/unit with both methods. We
can also note that the throughput accounting demonstrates smaller net incomes after tax, mainly because GAAP accounting
considers inventories positively. The NIAT difference between GAAP and throughput accounting is always constant and does
not depend on the transfer price value. Therefore, the throughput accounting always accounts $186,135.08 less net income
before tax than GAAP accounting, as long as the inventory values do not change. Thus, the transfer price is the same for both
GAAP and TA, but it is impacted and increases as inventory levels increase.
We ran another sensitivity analysis. However, this time, we varied the inventory values. We set both safety stock variables
to range from 0 (run 1) to 5000 (run 5) units, with incremental increases set at 1250 units in each run. It is important to note
that, as we increase safety stock, the overall inventory level of the system also increases, as the model produces more in order
to maintain the minimum level of inventory required, i.e. safety stocks. Fig. 7 demonstrates the charts of total net income after
tax versus the safety stock variation, with each point representing a different run of the sensitivity analysis.
Once again, the GAAP favours the net income after tax as the levels of inventory increase. It is possible to note that the NIAT
is much higher with more inventory in GAAP than in TA. However, this time, the difference between GAAP and throughput
accounting is not constant. To better observe the behaviour of the throughput NIAT with the inventory levels, we used
sensitivity analysis, once again comparing the inventory levels and the NIAT difference between GAAP and TA. Fig. 8 presents
the simulation results. We used 10 runs varying safety stocks in A and B, with ranges set from 0 (run 1) to 9000 units (run 10)
and incremental increases set at 1000 units for each run.

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

Fig. 5. Aggregative sectors of the model. Prepared by the authors.

This time the difference between GAAP and throughput accounting seemed different. In the beginning, growth was
observed when the inventory level was low, and then it became linear in run 4 and onwards. This happened mainly due to the
variation in demand. When the safety stock was low, both Units kept less inventory. Since inventory levels were lower, all the
inventory was consumed by the demand. After run 6, the safety stock levels could be maintained, and no sales were lost. Until
run 6, we may have had a capacity constraint, for instance, while, from run 6 and onwards, the constraint became the demand.
It is possible to observe then that TA accounts NIAT in a different manner when the demand is not entirely met. Also, the TA
more closely follows the increase in inventory than GAAP, as higher inventory increases NIAT considerably less than GAAP
does. Next, we demonstrate the pattern of demand and consumption observed with two more simulations. In one, safety
stocks were set at 1000 units, while, in the other, these were set at 6000 units. Fig. 9 shows the results. The top graph (a) has
the results with inventories set at 1000 units, and the other (b) at 6000 units.
As can be seen in the chart above, when inventory levels are lower, sales are lost, and demand is not met entirely. For this
reason, the revenue is affected, which, in turn, affects the net income after tax. Thus, as we keep more inventory, the
throughput accounting becomes more “punitive” than the GAAP accounting method. Once the inventory levels are kept
constant e through safety stock e the difference between GAAP and TA stabilises as well.

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

Fig. 6. Total NIAT vs. TP. Prepared by the authors.

Fig. 7. Total NIAT vs. Total Inventory Levels. Prepared by the authors.

Complementing the analysis, we conducted the same simulations once again, but, this time, with an increased value for
the standard deviation of demand. Instead of 1,000, we set the normal curve standard deviation at 5000 units. The increase in
demand variation would create an example that would be a more realistic demand distribution. Fig. 10 shows the results of
these simulations.
Increasing demand variation leads to increases in the inventory levels e as a security measure e in order to meet the
required demand. In part (a) of Fig. 10, it is possible to observe that the optimal transfer price moves from around $14 to
approximately $16 for both accounting methods, once again demonstrating the effects of increasing inventory levels in the
transfer price. This is the expected result, as the variation of demand results in more inventory to meet demand. The NIAT is
also impacted by the increased variation, as can be observed in part (b) the NIAT in TA is much lower than GAAP when the
inventory is higher. As can be seen in parts (b) and (c), as the demand variation increases and, consequently, the inventory
increases, the differences between the GAAP and TA become more significant in terms of absolute values. This happens due to
the increase in inventory levels that are not positively accounted under TA. Lastly, Fig. 11 demonstrates the sales and demand
over time when safety stocks are set at a) 1000 units and b) 6000 units.
It is possible to notice that the lost sales increase, meaning that the demand is not met more frequently and by greater
differences. Even when safety stocks were set at higher levels, the demand could not be met entirely, as may be seen in the
second chart of Fig. 11. The increase in lost sales also helps understanding of the differences between TA and GAAP, as seen in
chart (c) of Fig. 10. As we prejudice revenue and do not account inventories positively, the differences increase, and their
pattern varies. We can note that TA is more “punitive” in this sense. NIAT is impacted negatively in TA if there are lost sales and

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

Fig. 8. NIAT difference between GAAP and TA vs. Inventory. Prepared by the authors.

the inventory surplus does not impact NIAT positively as much as it does in GAAP. In order to summarise the results and the
findings, we present Frame 1 below.
Frame 1 e Summary of the simulation results. Prepared by the authors.
Finally, to increase clarity of the findings, we present the results from the last set of simulations in Table 8. Therefore, the
values presented in the table show the NIAT with safety inventories ranging from 0 to 9000 units and demand variation set at
5000 units of standard deviation. Column ‘n’ represents the run number of the sensitivity analysis, according to the safety
inventory variation. The NIAT is shown for both accounting methods, as well as their incremental variation at each one of the
simulation runs in absolute and percentual values. The percentual difference in the NIAT is presented for the sake of com-
parison. Finally, the surplus inventory represents the amount of inventory accumulated at the end of the period and the lost
sales demonstrates the difference between demand and actual sales for the year.
It is possible to note that with increased variation, even with safety inventories set at 9000 to both units, the demand
cannot be entirely met, even though, as inventories increase the lost sales decrease incrementally. The difference in NIAT
between the TA and GAAP, for our example, can be as high as 70%. It increases as the model keeps surplus inventories, which
are penalised in TA. It can be pointed out that, although inventory is kept at the end of the year, sales are still lost, mainly due
to demand peaks during the period (see Fig. 10 (b)). There is a decrease in the NIAT from run 6 to run 7, mainly because the
surplus inventory does not increase the throughput e the throughput increases as lost sales decrease e sufficiently enough to
increase the NIAT and compensate the increase in inventories. Then, after run 7, we can see that as the inventories increase
and lost sales decrease linearly, the NIAT TA also improves, eventually becoming higher than the value found in run 6.
From the results, we understand that inventory levels play a major role in accounting and transfer pricing. Transfer prices
present an opportunity for profit maximisation for MNEs (Cecchini et al., 2013; Hammami & Frein, 2014b); but, we state that
inventory levels should be fully understood in order to reach TP real optimisation. As much as the overestimation of in-
ventories is an issue, it is necessary to not underestimate them as well. The definition of safety inventories, for instance,
should be considered carefully considering consumption patterns, demand variation and lead-times. Estimating inventory
levels can be a challenge due to the difficulty of achieving the optimal spot between avoiding lost sales and creating excess
inventory. Therefore, even though inventories are usually neglected by other studies (Sepp€ al€
a et al., 2014), as stated by Pong
and Mitchell (2006), their valuation can significantly impact organisations’ profitability. With this in mind, in our case, we
show that traditional accounting methods tend to overestimate the benefits e up to a 70% difference in NIAT e of inventories
that may lead to superficial analyses of increases in the net income after tax. In this sense, similarly, as briefly suggested by
Ronen and Pass (2008), we found that TA seems to be a reasonable alternative for management control, as it does not
overestimate inventory levels and focuses on the throughput (i.e. more sales).
One key point is that practitioners and/or managers make their decisions considering both their taxes and management
control objectives, as stated by Joseph et al. (2017) and Cecchini et al. (2013). In other words, would managers make the same
decisions regarding offshoring e knowing that it can lead to increased levels of inventory and longer lead-times when

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

Fig. 9. Sales and Demand vs. Time. Prepared by the Authors.

compared to onshore e if they knew that their net income after tax could be up to 70% lower than originally estimated? The
throughput accounting tries, in this case, to diminish this problem. Therefore, the TA can be used as a metric to support supply
chain decision-making regarding offshoring and transfer prices optimisation.

6. Concluding remarks

In this research, we aimed to fill a gap in management accounting and control regarding international TP settings (Cools &
Slagmulder, 2009). We propose the utilisation of throughput accounting and demonstrate the importance of inventories in
those scenarios. Our main contribution lies in the presentation of TA, from a management control perspective, as a valuable
alternative to GAAP e addressing, at the same time, some of the operational concerns from traditional accounting methods.
Additionally, we also contribute to a recent lack of research in TA (Hilmola & Gupta, 2015), as well as bridging a gap between
SCM and accounting literature (Joseph et al., 2017; Ramos, 2004). First, we conducted a literature review regarding transfer
pricing and throughput accounting. Then we created a system dynamics model to evaluate the transfer pricing and offshoring
scenario, comparing the traditional accounting methods to throughput accounting. The results demonstrated that
throughput accounting is stricter about inventory levels, which supposedly increase as supply chains are offshored.
From a practical point of view, we demonstrate that throughput accounting can support decision-makers to assess and
estimate offshoring benefits for MNEs. We showed that inventories and demand variation play an important role in such
scenarios and tend to be underestimated in traditional accounting methods, impacting both the optimal transfer price and the
net income after tax. We contribute to such studies as Joseph et al. (2017), demonstrating that, in an international TP setting,
managers have to account far more than just tax savings. Additionally, we contribute to the literature by comparing tradi-
tional accounting methods of inventories to other alternatives e in our case the TA e as pointed out by Pong and Mitchell

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

Fig. 10. Simulation with increased demand variation. Prepared by the Authors.

(2006) and demonstrating the impacts of different methods on profitability. Finally, from the SCM perspective, we propose a
method that does not neglect inventory costs as usually happens, as claimed by Seppa € l€
a et al. (2014), instead making it more
relevant to the respective setting. In fact, the differences between the TA and GAAP are up to 70% in NIAT, mainly due to
different accounting of inventories (which accounts positively only the variable costs of inventory) and its reliance on the
throughput.
We also acknowledge some limitations of our model. We believe that an improved model considering arm’s length
regulation and setting the transfer prices via throughput accounting with comparative analyses would be useful. Other than
this, we could also enhance the model to consider decisions for or against offshoring, adding capacity constraints to the
production units, and even adding more production units. However, many other variables would have to be added to the

16
G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

Fig. 11. Sales and demand with increased demand variation. Prepared by the Authors.

Table 8
Simulation Results. Prepared by the authors.

n Safety Inventory NIAT TA NIAT TAn - NIAT TAn- NIAT ($) NIATn - NIATn-1 NIAT and NIAT TA % Surplus Inventory Lost Sales
(units) ($) 1 difference (units) (units)

Absolute % Absolute %
1 e 464,829.96 e e 677,129.85 e e 31% e 26,916
2 1000 547,097.66 82,267.70 15.0% 856,228.63 179,098.78 20.9% 36% e 23,774
3 2000 631,287.33 84,189.67 13.3% 1,064,239.49 208,010.86 19.5% 41% e 20,774
4 3000 704,262.62 72,975.29 10.4% 1,283,978.87 219,739.38 17.1% 45% e 17,774
5 4000 749,974.79 45,712.17 6.1% 1,517,351.28 233,372.41 15.4% 51% e 14,774
6 5000 751,776.63 1801.84 0.2% 1,790,306.42 272,955.14 15.2% 58% 155 11,929
7 6000 648,205.68 103,570.95 16.0% 2,158,414.37 368,107.95 17.1% 70% 2155 10,929
8 7000 703,377.86 55,172.18 7.8% 2,362,570.98 204,156.61 8.6% 70% 4155 9929
9 8000 760,428.44 57,050.58 7.5% 2,564,751.25 202,180.27 7.9% 70% 6155 8929
10 9000 817,594.45 57,166.01 7.0% 2,766,785.09 202,033.84 7.3% 70% 8155 7929

model, thereby drastically increasing model complexity. Consequently, techniques such as exploratory modelling and analysis
(EMA) would seem to be a great opportunity for future research, as EMA is useful when information exists, but does not allow
specifying a single model that describes the behaviour of the system accurately enough (Kwakkel & Pruyt, 2013). Another
interesting factor that could be added to the model would be an evaluation of profit maximisation alongside supply chain
performance; the supply chain performance indicator could be calculated through data envelopment analysis (DEA), for
instance, and the mixing of both profit and performance measures could create a robust decision-making tool.
This research has provided more insights into the transfer pricing setting and the throughput accounting methodology.
Additionally, it has provided a preliminary model to simulate the transfer pricing and offshoring context, thereby contributing
to the understanding of the defined scope.

Appendix A. Supplementary data

Supplementary data to this article can be found online at https://doi.org/10.1016/j.bar.2021.101001.

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G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

References

Baldenius, T., Melumad, N. D., & Reichelstein, S. (2004). Integrating managerial and tax objectives in transfer pricing. The Accounting Review, 79(3), 591e615.
https://doi.org/10.2308/accr.2004.79.3.591
Bertrand, J. W. M., & Fransoo, J. C. (2002). Operations management research methodologies using quantitative modeling. International Journal of Operations
& Production Management, 22(Issue 2). https://doi.org/10.1108/01443570210414338
Blackburn, J. (2012). Valuing time in supply chains: Establishing limits of time-based competition. Journal of Operations Management, 30(5), 396e405.
https://doi.org/10.1016/j.jom.2012.03.002
Borkowski, S. C. (2002). Electronic commerce , transnational taxation , and transfer Pricing : Issues and practices. International Tax Journal, 1, 36. http://
heinonline.org/HOL/Page?handle¼hein.journals/intaxjo28&div¼17&g_sent¼1&collection¼journals.
Boyd, L. H., & Cox, J. F. (2002). Optimal decision making using cost accounting information. International Journal of Production Research, 40(8), 1879e1898.
https://doi.org/10.1080/00207540210122239
Bragg, S. M. (2011). Management accounting best practices: A guide for the professional accountant (Vol. 1).
Brignall, S. (1997). A contingent rationale for cost system design in services. Management Accounting Research, 8(3), 325e346. https://doi.org/10.1006/mare.
1996.0049
Budd, C. S. (2010). Traditional measures in finance and accounting, problems, literature review, and TOC measures. In J. F. Cox, III, & J. G. Schleier (Eds.),
Theory of constraints handbook (pp. 335e372). McGraw-Hill.
Cecchini, M., Leitch, R., & Strobel, C. (2013). Multinational transfer pricing: A transaction cost and resource based view. Journal of Accounting Literature, 31(1),
31e48. https://doi.org/10.1016/j.acclit.2013.06.001
Chan, H. K., & Chan, F. T. S. (2010). A review of coordination studies in the context of supply chain dynamics. International Journal of Production Research,
48(10), 2793e2819. https://doi.org/10.1080/00207540902791843
Chen, I. J., & Paulraj, A. (2004). Understanding supply chain management: Critical research and a theoretical framework. International Journal of Production
Research, 42(1), 131e163. https://doi.org/10.1080/00207540310001602865
Christos, K., Dimitrios, B., & Dimitrios, A. (2016). Agent-based simulation for modeling supply Chains : A comparative case study. International Journal of New
Technology and Research, 2(10), 36e39.
Clempner, J. B., & Poznyak, A. S. (2018). Computing the transfer pricing for a multidivisional firm based on cooperative games. Economic Computation &
Economic Cybernetics Studies & Research, 52(1), 107e126. https://doi.org/10.24818/18423264/52.1.18.07
Cools, M., Emmanuel, C., & Jorissen, A. (2008). Management control in the transfer pricing tax compliant multinational enterprise. Accounting, Organizations
and Society, 33(6), 603e628. https://doi.org/10.1016/j.aos.2007.05.004
Cools, M., & Slagmulder, R. (2009). Tax-compliant transfer pricing and responsibility accounting. Journal of Management Accounting Research, 21(1), 151e178.
https://doi.org/10.2308/jmar.2009.21.1.151
Corbett, T. (1999). Throughput accounting. North River Press.
De Matta, R., & Miller, T. (2015). Formation of a strategic manufacturing and distribution network with transfer prices. European Journal of Operational
Research, 241(2), 435e448. https://doi.org/10.1016/j.ejor.2014.08.042
Drtina, R., & Correa, H. L. (2011). How transfer prices can affect a supply chain strategic decision. International Journal of Logistics Systems and Management,
8(4), 363. https://doi.org/10.1504/IJLSM.2011.039595
Dugdale, D., & Jones, T. C. (1998). Throughput accounting: Transforming practices? The British Accounting Review, 30(3), 203e220. https://doi.org/10.1006/
bare.1997.0062
Eccles, R. G., & White, H. C. (1988). Price and authority in inter-profit center transactions. American Journal of Sociology, 94, S17eS51. https://www.jstor.org/
stable/2780241.
Ernst & Young. (2016). EY - 2016 transfer pricing survey series - EY - global. https://www.ey.com/gl/en/services/tax/ey-2016-transfer-pricing-survey-series.
Feinschreiber, R. (2004). Transfer pricing methods: An applications guide. John Wiley & Sons, Inc.
Gao, L., & Zhao, X. (2015). Determining intra-company transfer pricing for multinational corporations. International Journal of Production Economics, 168,
340e350. https://doi.org/10.1016/j.ijpe.2015.07.006
Ge, H., Gray, R., & Nolan, J. (2015). Agricultural supply chain optimization and complexity: A comparison of analytic vs simulated solutions and policies.
International Journal of Production Economics, 159, 208e220. https://doi.org/10.1016/j.ijpe.2014.09.023
Goetschalckx, M., Vidal, C. J., & Dogan, K. (2002). Modeling and design of global logistics systems: A review of integrated strategic and tactical models and
design algorithms. European Journal of Operational Research, 143(1), 1e18. https://doi.org/10.1016/S0377-2217(02)00142-X
Goldratt, E. M. (1988). Computerized shop floor scheduling. International Journal of Production Research, 26(3), 443e455. https://doi.org/10.1080/
00207548808947875
Gupta, M. C., & Boyd, L. H. (2008). Theory of constraints: A theory for operations management. International Journal of Operations & Production Management,
28(10), 991e1012. https://doi.org/10.1108/01443570810903122
Hammami, R., & Frein, Y. (2014a). Integration of the profit-split transfer pricing method in the design of global supply chains with a focus on offshoring
context. Computers & Industrial Engineering, 76, 243e252. https://doi.org/10.1016/j.cie.2014.07.021
Hammami, R., & Frein, Y. (2014b). Redesign of global supply chains with integration of transfer pricing: Mathematical modeling and managerial insights.
International Journal of Production Economics, 158, 267e277. https://doi.org/10.1016/j.ijpe.2014.08.005
Hasani, A., Zegordi, S. H., Nikbakhsh, E., Hasania, A., Zegordia, S. H., Nikbakhsha, E., Hasani, A., Zegordi, S. H., & Nikbakhsh, E. (2014). Robust closed-loop
global supply chain network design under uncertainty: The case of the medical device industry. International Journal of Production Research, 53(5),
1596e1624. https://doi.org/10.1080/00207543.2014.965349
Hilmola, O. P., & Gupta, M. (2015). Throughput accounting and performance of a manufacturing company under stochastic demand and scrap rates. Expert
Systems with Applications, 42(22), 8423e8431. https://doi.org/10.1016/j.eswa.2015.06.056
Hilmola, O. P., & Li, W. (2016). Throughput accounting heuristics is still adequate: Response to criticism. Expert Systems with Applications, 58, 221e228.
https://doi.org/10.1016/j.eswa.2016.03.051
Horngren, C. T., Datar, S. M., & Foster, G. (2004). In J. M. Braga (Ed.), Contabilidade de Custos: uma abordagem gerencial (11th ed.). Pearson Education do Brasil.
Huh, W. T., & Park, K. S. (2013). Impact of transfer pricing methods for tax purposes on supply chain performance under demand uncertainty. Naval Research
Logistics (NRL), 60(4), 269e293. https://doi.org/10.1002/nav.21533
Hyde, C. E., & Choe, C. (2005). Keeping two sets of books: The relationship between tax and incentive transfer prices. Journal of Economics and Management
Strategy, 14(1), 165e186. https://doi.org/10.1111/j.1430-9134.2005.00038.x
Jones, T. C., & Dugdale, D. (1998). Theory OF constraints: Transforming ideas? The British Accounting Review, 30(1), 73e91. https://doi.org/10.1006/bare.1997.
0061
Joseph, K., O’Brien, T., & Correa, H. (2017). Tax strategies and organisational communication in MNC supply chains: Case studies. International Journal of
Logistics Research and Applications, 20(2), 105e128. https://doi.org/10.1080/13675567.2016.1206065
Kim, B., Park, K. S., Jung, S. Y., & Park, S. H. (2018). Offshoring and outsourcing in a global supply chain: Impact of the arm’s length regulation on transfer
pricing. European Journal of Operational Research, 266(1), 88e98. https://doi.org/10.1016/j.ejor.2017.09.004
Klassen, K. J., Lisowsky, P., & Mescall, D. (2017). Transfer pricing: Strategies, practices, and tax minimization. Contemporary Accounting Research, 34(1),
455e493. https://doi.org/10.1111/1911-3846.12239
Kumar, S., & Sosnoski, M. (2011). Decision framework for the analysis and selection of appropriate transfer pricing for a resilient global SME manufacturing
operation-a business case. International Journal of Production Research, 49(18), 5431e5448. https://doi.org/10.1080/00207543.2011.563835

18
G. da Silva Stefano, T.S. Antunes, D.P. Lacerda et al. The British Accounting Review xxx (xxxx) xxx

Kwakkel, J. H., & Pruyt, E. (2013). Exploratory Modeling and Analysis, an approach for model-based foresight under deep uncertainty. Technological
Forecasting and Social Change, 80(3), 419e431. https://doi.org/10.1016/j.techfore.2012.10.005
Law, A. M. (2014). Simulation modeling and analysis (5th ed.). McGraw-Hill.
€ ffler, C. (2019). Divisionalization and domestic transfer pricing for tax considerations in the multinational enterprise. Management Accounting Research,
Lo
45, 100646. https://doi.org/10.1016/j.mar.2019.07.003. November 2017.
Mansilha, R. B., Collatto, D. C., Lacerda, D. P., Wolf Motta Morandi, M. I., & Piran, F. S. (2019). Environmental externalities in broiler production: An analysis
based on system dynamics. Journal of Cleaner Production, 209, 190e199. https://doi.org/10.1016/j.jclepro.2018.10.179
Martins, J. C., Lacerda, D. P., Wolf Motta Morandi, M. I., Goldmeyer, D., & Piran, F. S. (2020). Systems dynamic modeling to analyze the systemic viability of
the combined use of regenerative converters and energy storage in a UPS manufacturer. Journal of Cleaner Production, 246, 118950. https://doi.org/10.
1016/j.jclepro.2019.118950
Matsui, K. (2011). Intrafirm trade, arm’s-length transfer pricing rule, and coordination failure. European Journal of Operational Research, 212(3), 570e582.
https://doi.org/10.1016/j.ejor.2011.01.012
Miller, T., & De Maria, R. (2008). A global supply chain profit maximization and transfer pricing model. Journal of Business Logistics, 29(1), 175e199.
Morecroft, J. D. W., & Robinson, S. (2005). Explaining puzzling dynamics: Comparing the use of system dynamics and discrete-event simulation. Proceedings
of the 23rd International Conference of the System Dynamics Society, 115. https://doi.org/10.1002/9781118762745.ch09
Naor, M., Bernardes, E. S., & Coman, A. (2013). Theory of constraints: Is it a theory and a good one? International Journal of Production Research, 51(2),
542e554. https://doi.org/10.1080/00207543.2011.654137
Narayanan, V. G., & Smith, M. (2000). Impact of competition and taxes on responsibility center organization and transfer prices. Contemporary Accounting
Research, 17(3), 497e529. https://doi.org/10.1506/KAPX-YQTE-GJPT-7D64
Noreen, E., Smith, D., & Mackey, J. T. (1995). Theory of constraints and its implications for management accounting: A report on the actual implementation of the
theory of constraints. Incorporated: North River Press.
Perron, S., Hansen, P., Le Digabel, S., & Mladenovi c, N. (2010). Exact and heuristic solutions of the global supply chain problem with transfer pricing. Eu-
ropean Journal of Operational Research, 202(3), 864e879. https://doi.org/10.1016/j.ejor.2009.06.018
Pidd, M. (2003). Tools for thinking: Modelling in management science (2nd ed.). John Wiley & Sons Ltd.
Pong, C., & Mitchell, F. (2006). Full costing versus variable costing: Does the choice still matter? An empirical exploration of UK manufacturing companies
1988e2002. The British Accounting Review, 38(2), 131e148. https://doi.org/10.1016/j.bar.2005.09.003
Pong, C., & Mitchell, F. (2012). Inventory investment & control: How have UK companies been doing? The British Accounting Review, 44(3), 173e188. https://
doi.org/10.1016/j.bar.2012.07.008
Ramos, M. M. (2004). Interaction between management accounting and supply chain management. Supply Chain Management, 9(2), 134e138. https://doi.
org/10.1108/13598540410527033
Ronen, B., & Pass, S. (2008). Focused operations management: Doing more with existing resources.
Rosenthal, E. C. (2008). A game-theoretic approach to transfer pricing in a vertically integrated supply chain. International Journal of Production Economics,
115(2), 542e552. https://doi.org/10.1016/j.ijpe.2008.05.018
Rossing, C. P. (2013). Tax strategy control: The case of transfer pricing tax risk management. Management Accounting Research, 24(2), 175e194. https://doi.
org/10.1016/j.mar.2013.04.008
Rossing, C. P., Cools, M., & Rohde, C. (2017). International transfer pricing in multinational enterprises. Journal of Accounting Education, 39, 55e67. https://doi.
org/10.1016/j.jaccedu.2017.02.002
Seppa €l €
a, T., Kenney, M., & Ali-Yrkko€ , J. (2014). Global supply chains and transfer pricing: Insights from a case study. Supply Chain Management, 19(4),
445e454. https://doi.org/10.1108/SCM-01-2014-0049
Siebers, P. O., Macal, C. M., Garnett, J., Buxton, D., & Pidd, M. (2010). Discrete-event simulation is dead, long live agent-based simulation! Journal of
Simulation, 72(10), 1e13.
Smolarski, J. M., Wilner, N., & Vega, J. G. (2019). Dynamic transfer pricing under conditions of uncertainty e the use of real options. Journal of Accounting and
Organizational Change, 15(4), 535e556. https://doi.org/10.1108/JAOC-08-2018-0083
Stentoft, J., Mikkelsen, O. S., Jensen, J. K., & Rajkumar, C. (2018). Performance outcomes of offshoring, backshoring and staying at home manufacturing.
International Journal of Production Economics, 199, 199e208. https://doi.org/10.1016/j.ijpe.2018.03.009. April 2017.
Sterman, J. D. (2000). Business dynamics: Systems thinking and modeling for a complex world. Management https://doi.org/10.1057/palgrave.jors.2601336.
Susarla, N., & Karimi, I. A. (2012). Integrated supply chain planning for multinational pharmaceutical enterprises. Computers & Chemical Engineering, 42,
168e177. https://doi.org/10.1016/j.compchemeng.2012.03.002
Sweetser, A. (1999). A comparison of system dynamics (SD) and discrete event simulation (DES). In Summer computer simulation conference (Vol. 17, pp.
83e87). Chicago.
Tako, A. A., & Robinson, S. (2012). The application of discrete event simulation and system dynamics in the logistics and supply chain context. Decision
Support Systems, 52(4), 802e815. https://doi.org/10.1016/j.dss.2011.11.015
Tulasi, C. L., & Rao, A. R. (2012). Review on theory of constraints. International Journal of Advances in Engineering & Technology, 3(1), 334e344.
Vann, C. E. (2016). Strategic benefits of integrating the managerial accounting function with supply chain management. Journal of Corporate Accounting &
Finance, 27(3), 21e30. https://doi.org/10.1002/jcaf.22138
Vidal, C. J., & Goetschalckx, M. (2001). A global supply chain model with transfer pricing and transportation cost allocation. European Journal of Operational
Research, 129(1), 134e158. https://doi.org/10.1016/S0377-2217(99)00431-2
Wang, Z., Gao, W., & Mukhopadhyay, S. K. (2016). Impact of taxation on international transfer pricing and offshoring decisions. Annals of Operations Research,
240(2), 683e707. https://doi.org/10.1007/s10479-013-1489-y
Zhang, X., Huang, S., & Wan, Z. (2016). Optimal pricing and ordering in global supply chain management with constraints under random demand. Applied
Mathematical Modelling, 40(23e24), 10105e10130. https://doi.org/10.1016/j.apm.2016.06.054

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