Fiscal Trust in Transfer Pricing: A Critical Literature Review and Construction of a Tripartite Conceptual Model. Evidence from Morocco

Résumé

Fiscal trust in transfer pricing is a multidimensional phenomenon that the literature has long approached in a fragmented manner, mobilizing either deterrence theory or fiscal psychology, without integrating them into a coherent framework adapted to the specificities of emerging economies. This article provides a critical and structured review of eight foundational theoretical bodies, namely deterrence theory, procedural justice, the Slippery Slope Framework, responsive regulation, neo-institutionalism, agency theory, psychological contract theory, and social exchange theory, and reconstructs on this basis the genesis of a tripartite conceptual model. The model is structured around institutional determinants (H1: legal certainty; H2: documentary coherence), organizational determinants (H3: technical competence; H4: procedural efficiency), and relational determinants (H5: perceived transparency; H6: quality of fiscal dialogue; H7: reciprocity and recognition). The five-stage abductive construction process is explicitly retraced, from the systematic review of theories through contextual anchoring in the Moroccan regulatory framework, including the CGI, Decree 2-16-571, the DGI Control Guide 2023, and Decree 2.22.1020 of December 2025. The article makes two main contributions. First, it characterizes a theoretical gap that the model seeks to address, arguing why no single framework, taken individually, accounts for fiscal trust in the TP context of a post-BEPS emerging economy. Second, it sets out the theoretical rationale for each hypothesis on the basis of the triangulation produced by the review.

JEL Classification: H26, H83, F23, K34, M41

Paper type: Critical literature review and conceptual model construction