“…Given these high stakes, transfer pricing is marked by substantial conflict, between corporate managers inside firms (Eccles, 1985), between corporations and states (Armstrong, 1998), and between states (Rixen, 2008). Thus transfer pricing has been subject to significant scrutiny on ethical and political grounds (Armstrong, 1998;Borkowski, 2005;Hansen et al, 1992;Mehafdi, 2000;Ylönen & Teivainen, 2017), increasingly so in recent years, where transfer pricing has become the subject of unprecedented regulatory initiative (Baudot & Cooper, 2021;R. C. Christensen & Seabrooke, 2022;Rogers & Oats, 2021).…”