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Transfer pricing

Specific transfer pricing topics

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Specific transfer pricing topics

Table of content

Front page
  • About transfer pricing
  • The significance of transfer pricing risks
  • Report and document transfer pricing information
  • The Tax Administration's audit process for transfer pricing cases
  • Written agreements for controlled transactions
  • On the comparability analysis
  • How to conduct a comparability analysis
    • Identify the controlled transaction and select the year
    • Broad-based analysis
    • Delineation of the controlled transaction
      • Comparability factors
      • Identification of terms in intra-group agreements
      • Functions, Assets, and Risks analysis (FAR Analysis)
      • Describe specific characteristics of what is being transferred, economic circumstances, and business strategies
    • Comparability and pricing
      • How to compare and price controlled transactions
      • Finding comparable transactions, explaining, and documenting the comparison base
      • Select a transfer pricing method and determine the arm's length price
  1. Specific transfer pricing topics
  2. How to conduct a comparability analysis
  3. Delineation of the controlled transaction

Describe specific characteristics of what is being transferred, economic circumstances, and business strategies

  • Published: 28 October 2025

An analysis of the transaction must include a description of what is transferred, a description of the market and economic conditions influencing the specific transaction, and how business strategies come into play.

    Figure: Illustration of the comparability analysis with a focus on the last three steps.

    Describe specific characteristics of what is transferred in the transaction

    You must describe the important characteristics of what is transferred in a transaction. The transferred item will often be a product or a service. The description should address both the expected market value and what you anticipate the transferred item will contribute to the business. For example, you should specify whether the transferred item is used in primary activities, meaning value-creating operations, or in support activities.

    The description of the characteristics of the transferred item should be based on the type of asset, such as:

    • For tangible items, specific characteristics may include quality, capacity, or reliability.
    • For services, specific characteristics may include the nature of the service, job description, or scope.
    • For intangibles, specific characteristics may include the category (e.g., trademark, logo) or degree of legal protection (e.g., patent).

    Describe the economic circumstances of the transaction parties and the market

    In the market analysis, you describe the conditions that influence pricing and market dynamics where the transaction takes place. The broader analysis can serve as a useful starting point, but in this section, you link the description of market conditions more specifically to the transaction you are delineating.

    Examples of factors that may be important to describe are:

    • Geographical location
    • Market size
    • Barriers to entry (new markets)
    • Level of competition (e.g., number of suppliers/demanders)
    • Competitive position of the buyer and seller (e.g., new entrants, market leaders, small/large)
    • Purchasing power in the market
    • Regulation (e.g., prohibitions, mandates, quota regulations, tariff barriers)
    • Economic cycles

    Describe the business strategies

    You must describe the business strategies of the group and the company and how these strategies affect the transaction (pricing and terms).

    Business strategies are long-term plans to achieve business goals. All strategies involve deliberate choices to maximise the return on capital invested in the group.

    The group and the company may have a range of strategies depending on both the characteristics of the product and the various market conditions/economic circumstances under which the business operates. Examples of strategies are innovation, market penetration, and diversification.

     The following questions can help identify the business strategies:

    • Are you the sole supplier/distributor/manufacturer within the group?
    • Do you engage in one or more types of transactions?
    • Is the current transaction part of an innovation or product development?
    • Does the current transaction target a new market or an established one?
    • What is the risk profile of the group, and what is the risk profile of the company?

     

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