Prisoverførsel

Prisoverførsel refers to the practice of setting prices for transactions between related entities within a multinational group. It covers the sale of goods, provision of services, transfer of intangibles, and financial arrangements across borders. The goal is to reflect economic substance and value creation, and to allocate profits between jurisdictions in a way that aligns with where activities occur and value is created.

The pricing should follow the arm's length principle, meaning that prices should be comparable to what independent parties would agree in similar circumstances. National tax authorities regulate transfer pricing to prevent profit shifting and base erosion. International guidelines, notably the OECD Transfer Pricing Guidelines and, for some jurisdictions, the UN Practical Manual, provide frameworks for determining appropriate pricing, documentation, and adjustments. In many countries, transfer pricing rules require documentation and may impose penalties for non-compliance.

Common methods include the comparable uncontrolled price (CUP) method, the resale price method, and the cost-plus method, as well as the transactional net margin method (TNMM) and the profit split method. Companies often choose the method based on available data and the nature of the transactions. Documentation typically includes a master file describing the business and a local file with transaction-specific details, and large multinationals may have country-by-country reporting requirements. Advance pricing agreements (APAs) are sometimes used to obtain agreement with tax authorities on the pricing approach.

Risks include adjustments by tax authorities, double taxation, and penalties for improper pricing. A well-documented transfer pricing policy supports compliance, minimizes disputes, and helps reflect actual value creation across the group.