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This paper examines transfer pricing in multinational firms when individual divisions face different income tax rates. Assuming that a firm decouples its internal transfer price from the arm's length price used for tax purposes, we analyze the effectiveness of alternative pricing rules under both cost- and market-based transfer pricing. In a tax-free world, Hirshleifer (1956) advocated that the internal transfer price be set equal to the marginal cost of the supplying division. Extending this solution, we argue that the optimal internal transfer price should be a weighted average of the pre-tax marginal cost and the most favorable arm's length price. When the supplying division also sells the intermediate product in question to outside parties, the external price becomes a natural candidate for the arm's length price. We argue that for internal performance evaluation purposes firms should generally not value internal transactions at the prevailing market price if the supplying division has monopoly power in the external market. By imposing intracompany discounts, firms can alleviate attendant double marginalization problems and, at the same time, realize tax savings due to differences in income tax rates. Our analysis characterizes optimal intracompany discounts as a function of the market parameters and the divisional tax rates.

Energy storage will be key to overcoming the intermittency and variability of renewable energy sources. Here, we propose a metric for the cost of energy storage and for identifying optimally sized storage systems. The levelized cost of energy storage is the minimum price per kWh that a potential investor requires in order to break even over the entire lifetime of the storage facility. We forecast the dynamics of this cost metric in the context of lithium-ion batteries and demonstrate its usefulness in identifying an optimally sized battery charged by an incumbent solar PV system. Applying the model to residential solar customers in Germany, we find that behind-the-meter storage is economically viable because of the large difference between retail rates and current feed-in tariffs. In contrast, investment incentives for battery systems in California derive principally from a state-level subsidy program.