Abstract:
Imagining cooperative tax regulation: Common origins, divergent paths.

In many countries, relational field dynamics between tax administrators and corporate taxpayers have undergone significant changes in recent years. We conceive of cooperative compliance models implemented in the Netherlands and the UK between large corporate taxpayers and the respective tax administrations as dynamic strategic action fields, nested within the wider tax field and influenced by shifts in the external environment. Drawing on a series of interviews with skilled actors we identify similarities between the two countries in terms of the initial motivation for introducing cooperative compliance. We also identify differences in the subsequent trajectories. We find that within the respective strategic action fields, an imaginary of cooperation built around mutual trust contributes to the sustainability of the field. Vulnerability to developments in proximate fields on the other hand undermines field sustainability. Together these concepts help to explain the different trajectories and demonstrate the value in exploring shared understandings in strategic actions fields as imaginaries and paying more attention to the influence of proximate fields. The findings have implications for regulatory policy design in other settings. 

Abstract:
Transfer pricing: changing views in changing times.

Transfer pricing for tax purposes has long been contentious, but recent political and public concerns about tax avoidance have energised critiques of current rules and debates about proposals for change. Transfer pricing tax rules are underpinned by the arm’s length principle and we consider how the common understanding of this principle has developed and changed, as criticism of it has grown and there have been increasing calls for change. In this qualitative study we draw on Bourdieusian concepts: we focus on the views of senior transfer pricing professionals relating to the UK and the US and consider how their views and transfer pricing practices have changed over a period of field disruption. This is important because calls for transformation of the field need to be cognizant of the extent to which existing practices are firmly embedded and thereby resilient to change. We find that over the period of our longitudinal study the senior transfer pricing professionals show a degree of adaptability to the use of the arm’s length principle, which continues to dominate.