Transfer Pricing 2.0 - A case study on the role of transfer pricing on the integration of MNCs after increased tax equality

Abstract: This paper employs the dynamic equilibrium model of paradox theory to analyze the role of transfer pricing on the integration of MNCs after increased tax equality. Findings suggest that the role under examination evolved as a consequence of the OECD BEPS project, ultimately reinforcing vicious cycles. Provoked by prevailing one-way thinking, increased tax equality further inhibited organizational actors to apply paradoxical viewpoint. Being deemed crucial to resolving paradoxes, this unilateral way of thinking, combined with individual factors of anxiety and consistency, finally lead to the role of transfer pricing on integration process within MNCs being found as a rather destructive than constructive, sustainable and resolving one.