Top Transfer Pricing (TP) Companies Norway

Transfer Pricing service is a cross-disciplinary service (economics, business, tax and legal) that helps multinational companies define proper pricing for their transactions between related parties in cross-border and sometimes also in domestic situations. Tax laws of most countries require that prices established between companies within the same group or under common control follow the arms' length principle, that is prices should correspond to market level as if buyer and seller are independent of each other. This ensures that profits earned in international transactions are fairly split and taxed among different jurisdictions.

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Transfer Pricing (TP) Businesses (10)

Sammen skaper vi verdier for deg og din virksomhet. Våre erfarne forretningsadvokater kjenner og forstår din bransje og deler sin kunnskap med deg.
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Experience in Transfer Pricing (TP)
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Our customer advisory team delivers sophisticated marketing solutions that result in unrivalled customer insights, acquisition and growth for your business.
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Experience in Transfer Pricing (TP)
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BDO er ledende innen revisjon, regnskap, rådgivning og advokattjenester i Norge. Våre kunder er alt fra store, verdensomspennende selskaper til små og...
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Experience in Transfer Pricing (TP)
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Vi bistår næringslivet med transaksjoner, komplekse prosjekter og tvister.
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Experience in Transfer Pricing (TP)
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Advokatfirmaet Wiersholm har røtter over hundre år tilbake i tid. Vi er i dag et av Norges største advokatfirmaer og har ekspertise på alle vesentlige områder innen forretningsjus.
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Experience in Transfer Pricing (TP)
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Grant Thornton Norway
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Experience in Transfer Pricing (TP)
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Experience in Transfer Pricing (TP)
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Arntzen de Besche er et ledende norsk advokatfirma. Våre kontorer i Oslo, Stavanger og Trondheim har nærmere 180 medarbeidere. Våre erfarne forretningsadvokater forenkler kompliserte transaksjoner, gjennomfører krevende forhandlinger og løser tvister.
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Experience in Transfer Pricing (TP)
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Advokater som er spesialister på eiendoms- og entreprisebransjen, og har et sterkt kompetansemiljø innen restrukturering og plan- og bygningsrett.
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Experience in Transfer Pricing (TP)
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Experience in Transfer Pricing (TP)
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Learn more about Transfer Pricing (TP)

Service Information

What business typically requires this service?

Typically, it is Multinational companies that have to prepare Transfer Pricing documentation by law and therefore need to carry out Transfer Pricing analysis and prepare documentation. However, in practice any public or private company with international operations may require Transfer Pricing services, for example if a company has foreign manufacturing subsidiary, or distributor in another country, or has employees working in several countries.

Companies can use Transfer Pricing services to:

  • define international Transfer Pricing policies
  • set appropriate prices and rates in related-party contracts
  • define proper commercial terms, allocate legal and commercial risks in related-party deals
  • allocate revenues, expenses or margins among group entities according to their value-adding involvement
  • defend appropriate pricing levels to tax authorities
  • prevent inadvertent tax disputes and claims

In which situations is this service relevant?

Transfer Pricing services are typically needed to define contractual prices in a cross-border context, for both tangible and intangible goods and services. For example:

  • sale of products or services via a related trading entity or distributor
  • purchase of goods or services through a related procurement company
  • production of goods by a related manufacturing facility
  • research and development carried out by a subsidiary or branch in one location for an entity in another location
  • royalties and licensing fees paid for Intellectual Property rights or software by companies in the same group
  • different administrative, marketing, management, consulting and other services provided or shared within a corporate group
  • complex joint venture setups with cost sharing or profits sharing arrangement

Some countries set out specific thresholds for transactions or turnover volume, when Transfer Pricing documentation becomes obligatory. Even if your business does not exceed such thresholds, it is advisable to meet certain minimal Transfer Pricing standards and perform basic TP analysis to prepare your business for growth and be compliant in all jurisdictions your business operates in.

What does the service include?

In a nutshell, a Transfer Pricing service analyses how functions, assets and risks are allocated between entities - parents, subsidiaries, head offices and branches - within corporate groups, in order to understand which entity in which jurisdiction deserves what portion of the international profits. This is known as functional analysis.

Transfer Pricing services also consider how goods and services sold between related parties compare to similar goods and services sold between independent parties under similar terms and market conditions. This is known as benchmarking study.

Results of the Transfer Pricing services are used in determining prices and margins that should be contractually arranged between related companies. Results and collected evidences of comparable transactions are recorded in Transfer Pricing documentation, known as Master file and Domestic files.