It’s an Art, Not a Science: Professionalisation and Global Governance in the Case of Transfer Pricing

Research output: Contribution to conferencePaperResearch

Abstract

Alongside the expansion of global trade in the 20th century, the discipline of transfer pricing – the pricing of transactions between related corporate enterprises – has grown from a minor technical inconvenience to being at the heart of global tax governance and of conflicts surrounding taxation of multinational enterprises. At the intersection of law, economics and accounting, transfer pricing has developed into an autonomous sphere of practice, which has profoundly shaped the structure and content of the international tax regime. Although it lacks the classical professions boundaries - licensing, distinct associations and a state-guaranteed monopoly – transfer pricing effectively functions in the same manner, protected and delineated by abstract specialised expertise associated with transfer pricing rules and methods. Despite a century of challenges, the cornerstone of transfer pricing practice, the arm’s length principle, which mandates related-party trade must accord to market terms, remain at the heart of today’s global tax governance. At the same time, global tax governance critically underpins the transfer pricing profession itself. This paper argues that this mutual interdependence – of global governance on the transfer pricing profession, and vice-versa – provides a new way of understanding the emergence of professional groups, of global governance, and of their interplay. Evidence is drawn from historical analysis, qualitative interviews and participant observation.
Alongside the expansion of global trade in the 20th century, the discipline of transfer pricing – the pricing of transactions between related corporate enterprises – has grown from a minor technical inconvenience to being at the heart of global tax governance and of conflicts surrounding taxation of multinational enterprises. At the intersection of law, economics and accounting, transfer pricing has developed into an autonomous sphere of practice, which has profoundly shaped the structure and content of the international tax regime. Although it lacks the classical professions boundaries - licensing, distinct associations and a state-guaranteed monopoly – transfer pricing effectively functions in the same manner, protected and delineated by abstract specialised expertise associated with transfer pricing rules and methods. Despite a century of challenges, the cornerstone of transfer pricing practice, the arm’s length principle, which mandates related-party trade must accord to market terms, remain at the heart of today’s global tax governance. At the same time, global tax governance critically underpins the transfer pricing profession itself. This paper argues that this mutual interdependence – of global governance on the transfer pricing profession, and vice-versa – provides a new way of understanding the emergence of professional groups, of global governance, and of their interplay. Evidence is drawn from historical analysis, qualitative interviews and participant observation.

Conference

ConferenceSASE 30th Annual Conference 2018
Number30
LocationDoshisha University
CountryJapan
CityKyoto
Period23/06/201825/06/2018
Other30th SASE Annual Meeting
Internet address

Bibliographical note

CBS Library does not have access the material

Cite this

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title = "It’s an Art, Not a Science: Professionalisation and Global Governance in the Case of Transfer Pricing",
abstract = "Alongside the expansion of global trade in the 20th century, the discipline of transfer pricing – the pricing of transactions between related corporate enterprises – has grown from a minor technical inconvenience to being at the heart of global tax governance and of conflicts surrounding taxation of multinational enterprises. At the intersection of law, economics and accounting, transfer pricing has developed into an autonomous sphere of practice, which has profoundly shaped the structure and content of the international tax regime. Although it lacks the classical professions boundaries - licensing, distinct associations and a state-guaranteed monopoly – transfer pricing effectively functions in the same manner, protected and delineated by abstract specialised expertise associated with transfer pricing rules and methods. Despite a century of challenges, the cornerstone of transfer pricing practice, the arm’s length principle, which mandates related-party trade must accord to market terms, remain at the heart of today’s global tax governance. At the same time, global tax governance critically underpins the transfer pricing profession itself. This paper argues that this mutual interdependence – of global governance on the transfer pricing profession, and vice-versa – provides a new way of understanding the emergence of professional groups, of global governance, and of their interplay. Evidence is drawn from historical analysis, qualitative interviews and participant observation.",
author = "Christensen, {Rasmus Corlin}",
note = "CBS Library does not have access the material; null ; Conference date: 23-06-2018 Through 25-06-2018",
year = "2018",
language = "English",
url = "https://sase.org/event/2018-kyoto/",

}

It’s an Art, Not a Science : Professionalisation and Global Governance in the Case of Transfer Pricing. / Christensen, Rasmus Corlin.

2018. Paper presented at SASE 30th Annual Conference 2018, Kyoto, Japan.

Research output: Contribution to conferencePaperResearch

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T1 - It’s an Art, Not a Science

T2 - Professionalisation and Global Governance in the Case of Transfer Pricing

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N1 - CBS Library does not have access the material

PY - 2018

Y1 - 2018

N2 - Alongside the expansion of global trade in the 20th century, the discipline of transfer pricing – the pricing of transactions between related corporate enterprises – has grown from a minor technical inconvenience to being at the heart of global tax governance and of conflicts surrounding taxation of multinational enterprises. At the intersection of law, economics and accounting, transfer pricing has developed into an autonomous sphere of practice, which has profoundly shaped the structure and content of the international tax regime. Although it lacks the classical professions boundaries - licensing, distinct associations and a state-guaranteed monopoly – transfer pricing effectively functions in the same manner, protected and delineated by abstract specialised expertise associated with transfer pricing rules and methods. Despite a century of challenges, the cornerstone of transfer pricing practice, the arm’s length principle, which mandates related-party trade must accord to market terms, remain at the heart of today’s global tax governance. At the same time, global tax governance critically underpins the transfer pricing profession itself. This paper argues that this mutual interdependence – of global governance on the transfer pricing profession, and vice-versa – provides a new way of understanding the emergence of professional groups, of global governance, and of their interplay. Evidence is drawn from historical analysis, qualitative interviews and participant observation.

AB - Alongside the expansion of global trade in the 20th century, the discipline of transfer pricing – the pricing of transactions between related corporate enterprises – has grown from a minor technical inconvenience to being at the heart of global tax governance and of conflicts surrounding taxation of multinational enterprises. At the intersection of law, economics and accounting, transfer pricing has developed into an autonomous sphere of practice, which has profoundly shaped the structure and content of the international tax regime. Although it lacks the classical professions boundaries - licensing, distinct associations and a state-guaranteed monopoly – transfer pricing effectively functions in the same manner, protected and delineated by abstract specialised expertise associated with transfer pricing rules and methods. Despite a century of challenges, the cornerstone of transfer pricing practice, the arm’s length principle, which mandates related-party trade must accord to market terms, remain at the heart of today’s global tax governance. At the same time, global tax governance critically underpins the transfer pricing profession itself. This paper argues that this mutual interdependence – of global governance on the transfer pricing profession, and vice-versa – provides a new way of understanding the emergence of professional groups, of global governance, and of their interplay. Evidence is drawn from historical analysis, qualitative interviews and participant observation.

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