Transfer pricing

Companies that have related transactions with contracting parties outside Norway must ensure that pricing is at arm’s length. This is to avoid profit shifting and base erosion. In addition, such companies may also be required to prepare the necessary documentation (“transfer pricing” documentation) that can document to the tax authorities that the pricing is at arm’s length. Preparation of transfer pricing documentation is not just a legal work. Assistance from other disciplines is also required. Ræder Bing has a collaboration with an external transfer pricing team that allows us to prepare transfer pricing documentation in accordance with OECD guidelines and Norwegian rules.
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Assistance provided

  • Preparation of internal pricing policy
  • Review of internal pricing agreements
  • Preparation of new internal pricing agreements
  • Identifying intra-group transactions
  • Collection of analyses of independent pricing (benchmarking)
  • Preparation of Master File
  • Preparation of Country File
  • Investigation from the tax authorities and challenge decisions from the tax authorities
  • Advise on structuring the group

 

If you have any questions or need assistance, our transfer pricing team can be contacted.

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