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Conceptualising the Behaviour of MNEs, Tax Authorities and Tax Consultants in Respect of Transfer Pricing Practices – A Three-Layer Analysis

Author

Listed:
  • Wealth Eukeria

    (Department of Tax and Auditing, School of Accounting, University of Namibia, Windhoek, Nambia)

  • Smulders Sharon A.

    (Department of Financial Intelligence, College of Accounting Sciences, University of South Africa, Pretoria, South Africa)

  • Mpofu Favourate Y.

    (Post-Doctoral Research Fellow, University of Johannesburg, Johannesburg, South Africa)

Abstract

This study explores the decision-making behaviour of economic actors in relation to transfer pricing by applying a three-layer practice theory. A critical review of the literature using snowball sampling and a thematic analysis of interview data from the Ministry of Finance, tax consultants and the Zimbabwe Revenue Authority bring to light novel conceptualisations and perspectives on the transfer pricing phenomenon. This study addresses scholarly gaps by exploring a confluence of legal, implementation and exploitative dimensions in transfer pricing regulation. The study also makes a novel contribution by proposing a model that could be useful to policymakers and tax authorities in ameliorating tax avoidance through transfer pricing.

Suggested Citation

  • Wealth Eukeria & Smulders Sharon A. & Mpofu Favourate Y., 2025. "Conceptualising the Behaviour of MNEs, Tax Authorities and Tax Consultants in Respect of Transfer Pricing Practices – A Three-Layer Analysis," Accounting, Economics, and Law: A Convivium, De Gruyter, vol. 15(2), pages 155-184.
    • Handle: RePEc:bpj:aelcon:v:15:y:2025:i:2:p:155-184:n:1005
    DOI: 10.1515/ael-2022-0036
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    More about this item

    Keywords

    transfer pricing; tax avoidance; impression management; MNEs;
    All these keywords.

    JEL classification:

    • H2 - Public Economics - - Taxation, Subsidies, and Revenue
    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance

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