Transfer pricing

Transfer pricing is, as a concept, primarily associated with how Norwegian and foreign tax authorities increasingly pay attention to cross-border transactions, but some requirements for reporting and documentation also apply to Norwegian corporations with no foreign operations.
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The fact that international conditions get the most attention, can probably be linked to how the OECD countries have introduced and are introducing a number of new rules that makes it necessary to review existing structures, intra-group agreements, reporting routines and internal pricing reports. Corporations that do not comply with the regulations in all countries where they operate, may leave key figures to be determined by the discretion of local tax authorities. This increases the risk of incurring additional tax bills, and in some cases even forfeiture of the right to complain.


At Ræder, we have lawyers thoroughly experienced with all types of transfer pricing issues, and we cooperate with acclaimed tax experts in most countries concerned. Through us, clients get independent advice and a review of their corporation’s tax issues, and we can handle virtually all necessary tasks in relation to this. Some of the work we perform for our national and international customers includes the following:

  • Establish and assess a corporation’s transfer pricing policy
  • Map requirements for transfer pricing reporting and documentation
  • Produce transfer pricing documentation
  • Assistance in dealings with tax authorities, both in Norway and internationally
  • Complaints handling
  • Procedure in courts
  • Questions related to transfer pricing, including agreements with the IRS on pricing and settling double taxation issues, APA (Advanced Pricing Agreements) and MAP (Mutual Agreement Procedure)

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