Transfer pricing process : Pricing of intragroup transactions
Häggblom, Malin (2018)
Häggblom, Malin
Centria-ammattikorkeakoulu
2018
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Julkaisun pysyvä osoite on
https://urn.fi/URN:NBN:fi:amk-2018060412253
https://urn.fi/URN:NBN:fi:amk-2018060412253
Tiivistelmä
Companies that are part of an intragroup are required to price the intragroup transactions according to the arm’s length principle. The purpose of this thesis was to gain knowledge of pricing methods within transfer pricing and how to perform the comparability analysis that shows that the transfer pricing applied is according to the arm’s length principle.
The theoretical part of this thesis discusses the OECD instructions of transfer pricing methods and the comparability analysis required in relation to the transfer pricing method selected. The thesis is restricted to the pricing of products, services, intangible assets and financing within the intragroup of Company X and give suggestions for corrections that needs to be made based on the knowledge acquired.
The goal of this thesis was achieved and suggestions for the update of the transfer pricing for the different types of transactions have been outlined. This thesis shows the transfer pricing methods that can be applied for intragroup transactions and how to perform the comparability analysis for the transfer pricing method applied.
The theoretical part of this thesis discusses the OECD instructions of transfer pricing methods and the comparability analysis required in relation to the transfer pricing method selected. The thesis is restricted to the pricing of products, services, intangible assets and financing within the intragroup of Company X and give suggestions for corrections that needs to be made based on the knowledge acquired.
The goal of this thesis was achieved and suggestions for the update of the transfer pricing for the different types of transactions have been outlined. This thesis shows the transfer pricing methods that can be applied for intragroup transactions and how to perform the comparability analysis for the transfer pricing method applied.