transferpricingnäkökohdat

Transfer pricing refers to the prices charged for transactions between related parties within a multinational enterprise, including the sale of goods, provision of services, use of intangibles, and intragroup financing. The setting of these prices influences how profits and tax obligations are allocated across jurisdictions and should reflect value creation rather than allocation based on tax considerations alone.

The governing principle is the arm's length principle, under which prices should be the same as those that would be agreed between unrelated entities operating in similar circumstances. Tax authorities use this principle to prevent intentional profit shifting to low-tax jurisdictions and to ensure profits are taxed where the underlying economic activity occurs.

Common methods fall into traditional transaction methods—comparable uncontrolled price, resale price, and cost plus—and transactional profit methods, such as the transactional net margin method and the profit split method. Selection depends on data availability, comparability, and the nature of the transactions.

Governments and international bodies, notably the OECD, publish guidelines and BEPS measures to standardize practice. Multinationals maintain documentation such as a Master File, Local File, and Country-by-Country Report to show how transfer prices were determined and to support potential audits.

Enforcement can require adjustments, interest, and penalties, and may result in double taxation without relief procedures like mutual agreement procedures or competent authority negotiations. Effective transfer pricing requires cross-border collaboration, robust data, and ongoing review to align with evolving rules and economic reality.