Transfer pricing: changing views in changing times

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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.

Keywords

  • International tax, arm's length principle, professionals, transfer pricing, transnational governance
Original languageEnglish
Pages (from-to)83-107
Number of pages25
JournalAccounting Forum
Volume46
Issue number1
Early online date1 Jul 2021
DOIs
Publication statusPublished - 2 Jan 2022

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