siirtohinnoittelupolitiikka

Siirtohinnoittelupolitiikka refers to the pricing practices used when goods or services are transferred between related entities within a multinational enterprise. These entities can be parent companies and their subsidiaries, or subsidiaries located in different countries. The core principle is that these internal transactions should be priced as if they were conducted between unrelated parties at arm's length. This "arm's length principle" is a cornerstone of international tax law, aimed at preventing the artificial shifting of profits from high-tax jurisdictions to low-tax jurisdictions.

When companies establish internal pricing for goods, services, intangibles like patents or trademarks, or loans between related parties, they must adhere to siirtohinnoittelupolitiikka. This involves selecting an appropriate transfer pricing method, such as comparable uncontrolled price, cost plus, resale price, transactional net margin, or profit split. The chosen method must accurately reflect the economic reality of the transaction and the functions performed by each entity.

Tax authorities scrutinize siirtohinnoittelupolitiikka to ensure that taxable profits are reported in the correct countries. If a company's transfer pricing is found to be non-compliant, tax authorities can adjust the prices, leading to reassessments and potential penalties for the company. Therefore, multinational enterprises invest significant resources in developing, documenting, and implementing robust siirtohinnoittelupolitiikka to comply with tax regulations and minimize tax risks across different jurisdictions. This often involves detailed economic analyses and documentation to support their chosen pricing strategies.