Transfer Pricing i Danmark & USA: En komparativ og terminologisk analyse

Sefija Ceric

Student thesis: Master thesis


Over the past decade there has been an increased focus on transfer pricing due to continuous globalisation and increased international trade. National boundaries are becoming less important for enterprises in general, but also for enterprises that engage in controlled transactions with affiliated enterprises within the same group. In case these transactions are not in agreement with market terms it is contrary to the interests of tax authorities as they are subject to substantial tax revenue losses. This has resulted in the implementation of more stringent regulations on an international as well as a national level necessitating companies to take a position on transfer pricing, develop a transfer pricing policy and most importantly to document how prices, terms and conditions are set in connection with controlled transactions. Thus, overseas trade emphasizes the need of understanding the transfer pricing systems of other countries not only due to judicial factors but also from a communicative perspective. Distinct differences exist between the Danish and American regulations, which from a translational and terminological perspective are interesting and challenging. In order to communicate on a professional level a suitable translation theory, correct concepts and technical terms are required. The thesis has three main aims: first, to conduct a comparative analysis of the transfer pricing guidelines in Denmark and USA in order to identify differences and similarities, second, to put translation of LSP texts concerning the subject in a theoretical context, and third, to analyse whether the identified differences and similarities have any influence on the terminological aspect of the subject. The first part of the thesis contains the comparative analysis, which has shown that the Danish system is characterised by a more rigid structure as it sets out more specific rules that are to be complied with, while the American system is more complex but yet flexible as tax payers have more freedom of action. Similarities and differences of degree exist on a theoretical level as regards the fundamental features in the guidelines that is the Arm’s Length Principle, disclosure requirements, documentation requirements and transaction-based transfer pricing methods. Distinct differences exist as regards the specific content of the guidelines and the practical execution, which is of significance for the translation process that is the translational approach, which depends on the purpose of the text and the target group. The second part of the thesis contains the terminological analysis of 15 Danish and American key terms, which has shown that transfer-pricing terminology is very specialised. In some cases it was possible to find equivalents e.g. The Arms Length Principle, but as the two systems in some respects are completely different several terms were so characteristic and specialised that it was necessary to develop translation suggestions. It was also established that terminological choices depend on the target group. If the target group are laymen explanations are required, whereas, if the target group are experts technical terms can be used to a large extent. In the conclusion it was established that the two transfer pricing guidelines are not identical. Although, similarities and differences of degree exist, which are not challenging from a translational perspective, the two systems are also marked by a number of distinct differences, which influence the terminology and result in translational challenges, as there is not equivalence between the two languages. It was also established that the translational approach and terminological choices depend highly on the purpose of the text, general or specific dissemination of knowledge, and the target group, laymen or experts.

EducationsMA in International Business Communication (Intercultural Marketing), (Graduate Programme) Final Thesis
Publication date2009
Number of pages111