e-journal
Transfer pricing: aligning the research agenda to organizational reality
Purpose – The purpose of this paper is to critically review the empirical transfer pricing literature as
a means of determining the agenda for future research.
Design/methodology/approach – The review is carried out primarily by searching databases,
academic journals and books. Second, professional surveys are reviewed to inform the development of
research ideas.
Findings – The understanding and ability to explain international transfer pricing in practice remain
limited despite a rapidly increasing tax regulatory pressure on multinational enterprises. One important
explanatory factor is that accounting and tax research has not been integrated to a sufficient extent. As
a consequence, rather isolated research streams and knowledge building have taken place, failing to
leverage the synergies of a combined research approach.
Research limitations/implications – A stronger emphasis on the outcome of specific transfer
pricing system designs would improve the literature’s current status in terms of whether the objectives
aimed at by the system are actually achieved. A new framework and promising research questions are
proposed to guide future work on this issue.
Practical implications – The proposed framework may serve as guidance for practitioners seeking
to assess the performance of specific transfer pricing systems and potentially provide directions for
refinement of current system designs when dysfunctional consequences are identified.
Originality/value – Previous transfer pricing research has taken a rather isolated approach. This
paper is an attempt to guide future transfer pricing research towards an inter-disciplinary approach.
Keywords Performance measurement, Transfer pricing, Management control systems,Accounting change, Accounting in global corporations and less developed countries, Cost and managerial accounting
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