Kvalitativ analys av Holmen Skogs internprissättningsmodell
Abstract: Transfer pricing has attracted considerable interest among tax authorities in recent years. One of the reasons for this is that various countries have now begun to protect their own tax bases to a greater extent than they did in the past. Sweden has introduced a law on the documentation on the grounds that the tax office to review the pricing of transactions that occur within multinational corporations. The purpose of the law is that companies should apply a transfer pricing that meet arm's length principle, which means that internal pricing reflects market prices. The EU Commission has, together with the EU member states formed a Forum, the EU Joint Transfer Pricing Forum (JTPF), since cross-border trade within groups constitute a threat to the internal market. The Forum has drawn up a code of conduct which includes a model of documentation. This code of conduct is described in the EU Transfer Pricing Documentation (EUTPD). The Holmengroup has decided to use the EUTPD rules when it comes to describing the group's pricing. One of the group's business units are Holmen Skog, which has the task of providing the group's swedish industries with raw material. To meet the need of raw material a company in Estonia is established. There are cross-border timber trade between Holmen Skog and the estonian subsidiary, Holmen Mets. The purpose of the thesis is to describe Holmen Skogs current transfer pricing method in a model, regarded to documentation obligation and arm's length principle. By using pricing theories and the OECD proposed transfer pricing methods similarities were noted as well as deviations from the set of guidelines for pricing. The result of this thesis shows that a sustainable transfer pricing strategy means that there is no reason for tax administration in Estonia nor in Sweden to suspect that the companies move profits from one country to another. In Estonia, corporation tax was abolished and Holmen Skog believes that Holmen Mets profits are on an acceptable level. At present, there are no thoughts that Holmen Skog make use of the tax system because either the swedish or the estonian tax authorities have questioned the companies' reported profits. The company's commitment is to source the raw material for a cost within the group. The basic principle is that the transfer must correspond to companies of all acquisition costs with a reasonable markup. Transfer pricing decisions reviewed on a quarterly basis and then taken into account Holmen Mets income statement and an estimate of companies' acquisition costs. From these data are estimated volume and transfer prices, which means that the subsidiary's results will either be adjusted or remain unchanged. An analysis of the empirical study shows that the company's current transfer pricing method characterizes a self costplus method. This requires EUTPD rules, a detailed description of the current transfer pricing method structure and how to get arm´s lengths prices in transactions between the two companies.
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