Abstract
Transfer pricing is a challenging problem for MNEs. This research reports quantitative results from a survey of Taiwanese MNEs operating in China, indicating differences between method frequency domestically and internationally, and mainly authoriarian top down transfer pricing decision-making. A transfer pricing system, based on the viable system model (VSM), is proposed to introduce an open systems holistic approach. The proposed VSM transfer pricing system is applied in seven MNEs, and the outcome of the applications is reported from interviews with CEOs. The proposed VSM transfer pricing system was reported to lead to improved transfer pricing decision-making, because of more complete information, integrated information flow, people know their responsibilities, more accountability, fewer conflicts, more participation, and more proactivity.
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