Transfer pricing problematikkens betydning for internationale koncerner: Illustreret ved et praktisk eksempel i Georg Jensen A/S

Louise Vedel Petersen

Student thesis: Master thesis


The increasing globalization has left international borders with less and less importance to international corporations. The result of this, among other things has been an increased interest in the topic transfer pricing among both foreign and Danish tax authorities. This has caused a growing number of transfer pricing cases as the respective tax authorities have identified a large, unexplored market within the transfer pricing and income distribution between the interests of connected parties. Foreign and Danish tax authorities are eager for potential tax revenues related to transfer pricing adjustments, obliging the Danish tax authorities to increase focus on this area in order not to lose potential tax revenue. The potential transfer pricing adjustments deal with large amounts of money because multinational corporations are involved. This international attention among tax authorities may result in "fights" since the possibility of both losses and gains of considerable scope exists. In 2006, the company tax authority requirements for information and documentation changed. As a result of these obligations, only few Danish companies do not need to consider transfer pricing issues today. For years there have been no real clarifications of transfer pricing rules in the Danish law concerning disclosure and documentation requirements. However, with the introduction of SKAT's two guides about disclosure and documentation requirements in 2000 and 2006, the area is set for a tightening of the processing of transactions with group related parties so that an operation’s reliability can be verified properly. The Danish tax authorities, despite the last two published guides, still recommend companies to follow the OECD Transfer Pricing Guidelines. One reason to this is that the level specification and description of pricing methods are described more thoroughly in the OECD Transfer Pricing Guidelines. The above actions by the tax authorities draw today many companies' attention to improve and / or prepare transfer pricing agreements with related parties. For Georg Jensen Group and Georg Jensen A/S as well as for many other groups, the above actions have increased incentives to focus on issues around transfer pricing, launch production of beneficial transfer pricing policies, and documentation of the transfer pricing to demonstrate that they fulfill the requirement for arm's length principle.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2010
Number of pages106