Documentation within Transfer Pricing : A case study

Abstract: Purpose: The overall purpose of this thesis is to provide an analysis of the effects of the documentation requirements on transfer pricing and provide a clearer picture of the documentation requirements in transfer pricing. Furthermore, the purpose is to analyze whether the chosen method of Superfos is adequate related to the new regulations. Background: In 2007, new regulations concerning the documentation of transfer pricing was enacted in Swedish law based on OECD guidelines. This change has led to new internal guidelines for companies regarding their transfer pricing work since the requirements apply to both Swedish owned companies and foreign owned companies. Furthermore, with this change, a great uncertainty about the requirements is shared by companies. Method: This thesis has been conducted as a qualitative case study with Superfos as the case company. A deductive approach has been used and the collection of data consists of both primary and secondary data. Primary in the form of an interview with the finance manager at Superfos and secondary through the use of the Swedish tax authority's stated guidelines concerning transfer pricing as well as books, journals and databases. Conclusion: In the conclusion we present a clarifying model of the documentation in transfer pricing based on the data collected for this thesis. In six steps, a clarifying picture of the overview, company structure, transactions identification, functional analysis, comparability analysis and results is provided.