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This paper aims to study the management of international transfer pricing (ITP) tax risks in multinational enterprises (MNEs). Specifically, the authors examine how in-house tax departments interact with business managers to implement tax strategies for ITP.

This paper is based on the case study method. The main empirical data consists of interviews with in-house accounting and tax professionals. The authors use social network theory and the notion of coercive versus enabling management styles as a lens for explaining the dynamic between centralized tax departments and local business managers.

The authors find that tax departments are not merely technocratic silos that mechanically administer and enforce the organizational implementation of ITP policies. Rather, tax departments are actively working to market themselves as enabling business partners to local business managers by using deliberate schemes of relationship building to accomplish tax strategy objectives.

Corporate taxes are a vital component for financing critical infrastructure, such as hospitals, schools, roads, bridges, water and electric systems. The work contributes to a contemporary discussion on MNEs’ tax strategies, including how they organize tax risk management processes for ITP.

Accounting research has mainly focused on the technical and regulatory details of ITP while ignoring the interpersonal aspects of tax risk management in MNEs. The authors argue that today’s tax department professionals must possess not only technical expertise but also interpersonal skills. Such skills are critical for building intraorganizational relationships with business managers to facilitate the bottom–up information flows needed to manage ITP tax risks.

The purpose of this paper is to critically review the empirical transfer pricing literature as a means of determining the agenda for future research.

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.

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.

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.

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.

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.