Tax Strategy Control: The Case of Transfer Pricing Tax Risk Management

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This paper examines how a functional tax strategy impacts the management control system (MCS) in a multinational enterprise (MNE) facing transfer pricing tax risks. Based on case study findings it is argued that the MCS in a multinational setting is contingent upon the MNE's response to its tax environment. Moreover, the paper extends existing contingency-based theory on MCS by illustrating the role of inter-organisational network collaboration across MNE transfer pricing tax experts. This collaboration, caused by a widely dispersed tax knowledge base, fuels the formal interactive control system and reduces tax uncertainty. The paper adopts an interdisciplinary approach for explaining findings, using contingency-based theory and network theory at the inter-organisational level.

TidsskriftManagement Accounting Research
Udgave nummer2
Sider (fra-til)175–194
StatusUdgivet - jun. 2013


  • Tax risk management
  • Management control systems
  • Tax strategy
  • International transfer pricing
  • Inter-organisational networks