Conceptualising the Behaviour of MNEs, Tax Authorities and Tax Consultants in Respect of Transfer Pricing Practices – A Three-Layer Analysis

Abstract This study explores the decision-making behaviour of economic actors in relation to transfer pricing by applying a three-layer practice theory. A critical review of the literature using snowball sampling and a thematic analysis of interview data from the Ministry of Finance, tax consultants and the Zimbabwe Revenue Authority bring to light novel conceptualisations and perspectives on the transfer pricing phenomenon. This study addresses scholarly gaps by exploring a confluence of legal, implementation and exploitative dimensions in transfer pricing regulation. The study also makes a novel contribution by proposing a model that could be useful to policymakers and tax authorities in ameliorating tax avoidance through transfer pricing.