Transfer Pricing

Risk review

To make informed decisions, a sufficiently good basis is required. By reviewing existing business models from an operational and tax transfer pricing perspective, we can identify potential risk or improvement areas and thereby provide valuable insights to consider in the decision-making process.

Strategy and planning

Many countries have strict rules regarding transfer pricing to ensure that profits are reported accurately for tax purposes. A clear strategy helps secure compliance with these regulations and provides for transparent pricing policies and consistency across regions. By establishing solid, documented policies, companies are better equipped to defend their pricing practices if challenged.

A solid transfer pricing framework can also provide insights into market conditions, competitive positioning, and profitability, and therefore support better strategic planning and forecasting.

Value transfers, restructurings and organizational changes

Various initiatives within a group, such as expansions, divestments, cost savings, or organizational changes, can impact the applied transfer pricing strategies. Transferring an intellectual property right or conducting an internal restructuring can lead to a tax-triggering situation where the seller may be entitled to compensation for the value deemed transferred. This, in turn, can have tax implications.

We offer proactive transfer pricing advisory services that ensure compliance with relevant regulations while also considering opportunities to limit the tax impact.

Compliance

Today, there are high compliance requirements, and most countries have regulations stating that international groups of a certain size must have updated transfer pricing documentation in place. The design and content of this documentation should, in most cases, adhere to the OECD Transfer Pricing Guidelines (Master File/Local Files).

We ensure that the documentation we help prepare complies with both Swedish and International (OECD) requirements. For specific foreign territories where additional requirements may apply, we offer extra assurance through the extensive network of transfer pricing specialists within our global alliance partner, Quantera Global.

Dispute prevention and resolution

An organization may face situations where its established transfer pricing strategies are questioned by tax authorities. As part of our service offering, we can assist in developing defense strategies, communicating with tax authority representatives, and preparing relevant documentation.

We also offer support in connection with MAP processes (aimed at eliminating double taxation) and APAs (aimed at securing future transfer pricing strategies).