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
Common methods include the comparable uncontrolled price (CUP) method, the resale price method, and the cost-plus
Risks include adjustments by tax authorities, double taxation, and penalties for improper pricing. A well-documented transfer