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.