A Holistic Perspective on Transfer Pricing : A Qualitative Single-Case Study of an International Organization

Abstract: Background: A majority of world trade takes place within rather than between organizations. When transactions take place within an organization and external market forces are absent, internal prices must be developed. The pricing of these internal transactions gives rise to the topic of transfer pricing. Purpose: Previous papers within the transfer pricing field have tended to have a narrow focus where one or a few aspects of transfer pricing have been examined. This paper instead investigates multiple aspects of transfer pricing with guidance from previous literature, stakeholder theory, and institutional theory. By doing so, the aim is to generate a holistic view of how transfer pricing is managed in an international organization. Method: This paper is based on a constructionist standpoint and uses an abductive qualitative approach. The study is a single-case study where data is mainly collected by interviewing employees involved in transfer pricing. To analyze the collected data, thematic analysis is used. Conclusion: Transfer pricing can be understood as a necessity stemming from the internal transactions that were beneficial to the case organization. The findings of this paper indicate that the management of transfer pricing is influenced by a variety of aspects that must be balanced.