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Strategic Transfer Pricing: The Art of Pricing Inter-company Transactions between Sweden and China
Linköping University, Department of Management and Engineering, Business Administration .
Linköping University, Department of Management and Engineering, Business Administration .
2010 (English)Independent thesis Advanced level (degree of Master (One Year)), 20 credits / 30 HE creditsStudent thesisAlternative title
Strategisk Internprissättning : Att Prissätta Koncerninterna Transaktioner mellan Sverige och Kina (Swedish)
Abstract [en]

Background

International transfer pricing has been a highlighted issue during the last decades as country after country has revised and introduced new transfer pricing laws as a respond to the expanded globalization. Several countries are adopting similar approaches and the prime guiding principles are provided by the Organization for Economic Co-Operation (OECD). The international law as well as the laws of all 30 member countries is based on the OECD Guidelines.

Purpose

The purpose of this master’s thesis is to describe differences and similarities regarding the transfer pricing regulations in China and Sweden and to explain how a Swedish multinational enterprise (MNE) have to utilize and adjust their transfer pricing strategy when trading with group companies in China. The results then conclude into a step model for strategic transfer pricing.

Result

The differences between the regulations are mainly uncovered in the definition of associated parties and associated interest. The differences in the regulations are thus of minor importance and does not affect a Swedish MNE to any major extent. The challenging area is instead the conflict between the tax authority and the customs service. To enable this study, three Swedish MNEs are used as a case study. We discovered that all had very different transfer pricing strategies even though they are within the same industry and two of them even within same range of products. Out of this we made the conclusion that the strategy chosen is not just depending on what product or service you trade with but also the aim and purpose, the range of products and the structure of the company. International transfer pricing is a very complex issue that goes into nearly all business operations. The concept of transfer pricing can thus be broken down and simplified if the demands from the company is minor.

Place, publisher, year, edition, pages
2010. , 94 p.
Keyword [en]
Transfer Pricing, OECD guidelines, Regulatory compliance, Inter-company transactions, China and Sweden
National Category
Business Administration
Identifiers
URN: urn:nbn:se:liu:diva-58007ISRN: LIU-IEI-FIL-A--10/00763--SEOAI: oai:DiVA.org:liu-58007DiVA: diva2:330539
Presentation
2010-06-08, Rum A 37 Linköpings Universitet, 14:30 (Swedish)
Uppsok
Social and Behavioural Science, Law
Supervisors
Examiners
Available from: 2010-08-10 Created: 2010-07-15 Last updated: 2010-08-10Bibliographically approved

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CiteExportLink to record
Permanent link

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Cite
Citation style
  • apa
  • harvard1
  • ieee
  • modern-language-association-8th-edition
  • vancouver
  • oxford
  • Other style
More styles
Language
  • de-DE
  • en-GB
  • en-US
  • fi-FI
  • nn-NO
  • nn-NB
  • sv-SE
  • Other locale
More languages
Output format
  • html
  • text
  • asciidoc
  • rtf