TY - JOUR

T1 - Transfer pricing: changing views in changing times

AU - Rogers, Helen

AU - Oats, Lynne

N1 - ESRC funding at Exeter: ES/S00713X/1

PY - 2022/1/2

Y1 - 2022/1/2

N2 - Transfer pricing for tax purposes has long been contentious, but recent political and public concerns about tax avoidance have energised critiques of current rules and debates about proposals for change. Transfer pricing tax rules are underpinned by the arm’s length principle and we consider how the common understanding of this principle has developed and changed, as criticism of it has grown and there have been increasing calls for change. In this qualitative study we draw on Bourdieusian concepts: we focus on the views of senior transfer pricing professionals relating to the UK and the US and consider how their views and transfer pricing practices have changed over a period of field disruption. This is important because calls for transformation of the field need to be cognizant of the extent to which existing practices are firmly embedded and thereby resilient to change. We find that over the period of our longitudinal study the senior transfer pricing professionals show a degree of adaptability to the use of the arm’s length principle, which continues to dominate.

AB - Transfer pricing for tax purposes has long been contentious, but recent political and public concerns about tax avoidance have energised critiques of current rules and debates about proposals for change. Transfer pricing tax rules are underpinned by the arm’s length principle and we consider how the common understanding of this principle has developed and changed, as criticism of it has grown and there have been increasing calls for change. In this qualitative study we draw on Bourdieusian concepts: we focus on the views of senior transfer pricing professionals relating to the UK and the US and consider how their views and transfer pricing practices have changed over a period of field disruption. This is important because calls for transformation of the field need to be cognizant of the extent to which existing practices are firmly embedded and thereby resilient to change. We find that over the period of our longitudinal study the senior transfer pricing professionals show a degree of adaptability to the use of the arm’s length principle, which continues to dominate.

KW - International tax

KW - arm's length principle

KW - professionals

KW - transfer pricing

KW - transnational governance

U2 - 10.1080/01559982.2021.1926778

DO - 10.1080/01559982.2021.1926778

M3 - Article

VL - 46

SP - 83

EP - 107

JO - Accounting Forum

JF - Accounting Forum

SN - 0155-9982

IS - 1

ER -