Transfer pricing - tre diskurser: En sociologisk diskursanalyse af en skatteretligt problematik

Tobias Zorde

Student thesis: Master thesis


This master thesis evolves around the subject of transfer pricing from a tax-ation point of view. The concept of transfer pricing has been exposed to an increasing amount of attention the last couple of decades. This develop-ment may be viewed as a natural consequence of globalization in which barriers dissolve, information becomes increasingly mobile and, in effect, multinational enterprises have flourished and transactions cross national borders at a previously unheard of frequency. When such transactions are performed between related parties other forces than the self-interest of the individual party may be at work. Recognition of this fact immediately gives rise to questions about what consequences such relations might have upon transferred values and general conditions of these transactions – in particu-lar in relation to taxation of the individual parties in their respective coun-tries of residence. This, of course, is the central problem of transfer pricing and constitutes the reason for the massive eruption of attentio from tax authorities, multinational enterprises, governments, politicians, and even consumers. In the midst of all this attention, effective communication about the subject matter is burdened severely by the multiple interests of numerous stake-holders. It is the hypothesis of this master thesis, that the designation of “transfer pricing” is applied in several different discourses operating within mutually incompatible conceptual frameworks. In effect, the designation has no objective existence outside these discourses leading to the conclu-sion that no common denominator for understanding can be provided. Wheras this may be the case it is certainly possible to analyse the most dominating discourses and identify the sources of conflict. While such an endeavour will by no means fuse the varying discourses into a single one, it will create an awareness of the divided nature of the subject matter and create a space for transdiscoursive reflection. To uncover the natures of such conflicting discourses, a sociological strategy of analysis known as discourse analysis will be applied. The purpose of this effort is to make the structures of the discourses visible in order to identify the specific sources of conflict.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2012
Number of pages87