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In transfer pricing companies balance a situation where paying taxes to one state is always taking them away from the collected taxes of another state. A careful transfer pricing solution in one country may count as aggressive tax planning in the country where the transaction partner is located. We can help you select a solution and assist you in situations where tax authorities in some part of the world interfere with the solution.
Changes in operative business can have significant effects on the group’s transfer pricing model and lead to taxes being paid in the wrong countries, which is why it is important to consider the related effects to transfer pricing and taxation when changing the business model or restructuring the company.
OECD’s transfer pricing rules guide e.g. the documentation of transfer pricing. The ALP emphasises, more explicitly than before, that income should be taxed where value is created. This is why it is fundamental that the group’s value-creating factors are being described in transfer pricing documentation.