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Front-page of the Norwegian Tax Administration
Front-page of the Norwegian Tax Administration
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

Identification of terms in intra-group agreements

  • Published: 28 October 2025

The agreement serves as the best starting point for assessing the terms applicable to the transaction. Additionally, we emphasise the parties' conduct (substance) to delineate the transaction.

You can read more about agreements in Written agreements in controlled transactions.

Figure of the comparability analysis with focus on Contract Terms

 

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