## **Learning Outcomes**

After reading this article, you should be able to explain the challenges and solutions related to goal congruence in multinational organisations. You will understand how differences in tax regimes, transfer pricing strategies, and conflicting divisional and group objectives can affect performance management. You will be able to analyse how to align managerial motivation with maximising group profit while maintaining compliance with international regulations.

## **ACCA Advanced Performance Management (APM) Syllabus**

For ACCA Advanced Performance Management (APM), you are required to understand the management control issues unique to multinational structures, particularly those arising from operating in multiple countries and tax systems. This article addresses:

- The potential for goal incongruence in international divisional structures
- The impact of disparate tax regimes on transfer pricing and divisional performance
- The criteria and challenges in setting transfer prices for cross-border transactions
- Designing performance measures that support group-wide objectives over local divisional interests
- The need for compliance with international taxation and anti-avoidance rules

## **Test Your Knowledge**

_Attempt these questions before reading this article. If you find some difficult or cannot remember the answers, remember to look more closely at that area during your revision._

1. What is the main risk when multinational group divisions are free to set their own transfer prices in countries with different tax rates?
2. Explain why a transfer price that minimises global tax might not result in high divisional performance in a local manager’s report.
3. True or false? Goal congruence always exists when each division of a multinational maximises its own profit.
4. Name two compliance risks associated with transfer pricing decisions in multinational companies.

## **Introduction**

In multinational organisations, ensuring that divisional managers’ actions support the wider group’s aims is a complex task. Differences in tax rates, legal rules, and economic environments introduce unique risks of conflicts between local and group interests. Designing transfer pricing policies and performance measures that encourage goal congruence—so that what is good for the division is also good for the group—becomes challenging when tax minimisation and regulatory compliance are also required.

> **Key Term: goal congruence**
> The alignment of managers’ objectives and actions with the overall objectives and best interests of the organisation.

## Goal Congruence in Multinational Groups

### The Need for Alignment

Multinational companies often structure their operations as semi-autonomous divisions located in different countries. Each division may be measured and rewarded based on its own profit performance, but the group's overall objective is usually to maximise total after-tax profits. This is complicated by varying taxation laws across jurisdictions.

> **Key Term: transfer pricing**
> The price charged for goods or services exchanged between divisions of the same group, especially across different tax jurisdictions.
>
> **Key Term: local optimisation**
> When a manager acts to maximise the performance or profit of their own division, even if this reduces the overall profit of the group.

### Tax and Regulatory Considerations

Divisions located in high-tax countries may prefer to buy goods at higher transfer prices (shifting profit to lower-tax countries) to improve their own local results, while the group may prefer to set prices to minimise consolidated tax liability. There can be a tension between tax planning, fair divisional assessment, and compliance with local laws and anti-avoidance regulations.

> **Key Term: arm's length principle**
> The transfer price that would apply between unrelated parties in a free market, often required for tax compliance.

## Transfer Pricing and Tax Minimisation

Transfer prices can be used to shift reported profits between countries to take advantage of lower tax rates. While this can reduce the group’s total tax bill, setting artificial prices may breach tax regulations, attract fines, or damage relationships with tax authorities. In addition, local managers may perceive that tax-driven transfer prices do not fairly reflect their efforts or business performance.

### **Worked Example 1.1**

A group operates two divisions, A in country X (tax rate 40%) and B in country Y (tax rate 20%). Division A makes a component at a cost of \$8 and transfers it to B. The group can set a transfer price anywhere between \$8 and \$20, the external selling price. Group management proposes a low transfer price to shift profits to division B in the lower tax country.

**Question:** What is the likely effect on divisional performance evaluation and group tax liability?

> **Answer:**
> The low transfer price benefits the group by increasing profit taxed at 20% in B and reducing profit taxed at 40% in A, cutting the overall tax bill. However, division A’s reported profit—and possibly its manager’s bonus—will decline, causing potential dissatisfaction and demotivation. If performance evaluation and reward do not account for this, local managers may resist group policy.

### Setting Objectives and Performance Measures

To reduce conflict, group management should:

- Make divisional targets and bonuses independent of tax-driven transfer pricing, for example, by using “pre-tax” profit or by adjusting reported performance for transfer pricing.
- Communicate clearly why transfer prices are set as they are, emphasising group interest and legal requirements.
- Regularly review transfer price policies to remain compliant with local laws and international standards.

### **Worked Example 1.2**

A multinational’s electronics division in Country A (high tax) sells microchips to its assembly division in Country B (low tax). The group shifts profit to Country B by setting a low transfer price, but the tax authority in Country A challenges this and imposes penalties for not using an arm’s length price.

**Question:** What should the group have considered to prevent this outcome?

> **Answer:**
> The group should have checked local tax laws and applied an arm’s length transfer price as required by regulations. Compliance with both countries’ tax rules is essential. Failure to do so risks adjustments, penalties, and damage to the company’s reputation.

### Practical Challenges

- Changing exchange rates can affect the value of transfer prices and managers may be held responsible for currency movements they cannot control.
- Some countries impose restrictions on profit repatriation, limiting the effectiveness of transfer pricing as a tool for cash movement.
- Division managers may face legal and cultural pressures to prioritise local results over group performance.

### **Exam Warning**

> In APM exam scenarios, always consider whether the transfer pricing method supports group profit maximisation, regulatory compliance, and manager motivation. Ignoring compliance or the impact on local manager behaviour can cost marks.

### **Revision Tip**

> If asked to recommend a transfer pricing policy, balance tax minimisation, legal compliance, clear divisional performance evaluation, and effective communication with local managers.

## **Summary**

Multinational groups face special challenges in achieving goal congruence, particularly when transfer pricing decisions impact both tax liabilities and divisional evaluations. Aligning policies with tax rules and designing fair performance measures are key. Effective management means group profits are maximised, legal risks are minimised, and managers remain motivated.

## **Key Point Checklist**

_This article has covered the following key knowledge points:_

- Explain how tax differences across jurisdictions generate conflicts between divisional and group objectives
- Describe how transfer pricing can affect both performance measurement and tax minimisation
- Identify the importance of the arm’s length principle and compliance with local laws
- Recommend performance evaluation methods that minimise conflict and encourage group-oriented behaviour
- Recognise the requirement to separate managerial assessment from the effects of tax-driven transfer pricing

## **Key Terms and Concepts**

- goal congruence
- transfer pricing
- local optimisation
- arm's length principle

International context and taxation - Goal congruence across jurisdictions