Transfer pricing: Påvirkning af resultatfordelingen samt overholdelse af armslængdeprincippet i Dansk koncern JF. OECD's TPG 2017

Ea Makholm Corfitz Nielsen

Student thesis: Diploma thesis


The main focus of this exercise is to nuance and refine the already existing problem regarding the Transfer Pricing of a controlled transaction. In 2017, new clarifications of OECD TPG chapters 1, 6 and 9 were published, which is not necessarily something that all companies and business owners do not yet fully master. The issue with the distribution of intangible assets and costs between the companies will be examined, as it is important for companies to have insight into how to enter into agreements, so both parties (separately) have an advantage in concluding the agreements. The approach for the exercise is theoretical, where the theories are practiced by examples in the form of current articles by companies that are in similar situations as well as an own constructed business case. The focus is therefore the arm's length principle in accordance with OECD TPG Chapter 1, the handling of intangible assets in accordance to OECD TPG Chapter 6, and the treatment of internal group restructuring in accordance with OECD TPG Chapter 9. In the own constructed company case with Danish parent company as principal, intangible assets are moved to the Group's production company. In this internal group restructuring, functions, employees and transfer of risk are moved and the case will therefore analyze how there must be paid for compensation for the transfer of the intangible asset. With the new clarifications in TPG 2017 chapters 1, 6 and 9, the OECD tries to limit incorrect income allocation, and prevent a group company that supports a subsidiary from becoming a weak company, which moves capital between the group. The new clarifications also aim to ensure that group companies not only invest in intangible assets to earn returns. In the own constructed company case, OECD TPG chapters 1, 6 and 9 are used, thus it can be clarified what companies should be aware of when the company conducts controlled transactions. When a Danish parent company transfers "something of value", the company must receive compensation, while the receiving company must be remunerated by the added value created by the company.

EducationsGraduate Diploma in Accounting and Financial Management, (Diploma Programme) Final Thesis
Publication date2019
Number of pages83