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 literature using snowball sampling and thematic analysis interview data from Ministry Finance, tax consultants Zimbabwe Revenue Authority bring light novel conceptualisations perspectives on phenomenon. addresses scholarly gaps exploring confluence legal, implementation exploitative dimensions regulation. The also makes contribution proposing model that could be useful policymakers authorities ameliorating avoidance through pricing.