Does your group trade with a Swedish subsidiary or operate through a Swedish branch? Skattepunkten helps international businesses assess transfer pricing, support their pricing decisions and connect the Swedish requirements with the group's wider approach.
When related companies trade across borders, the price affects where profits are taxed. Tax authorities on either side may question the outcome. We help you work through what independent parties would have agreed, taking account of the transactions, the business and the evidence available.
A Swedish perspective on your group's transactions
Need help with transfer pricing in Sweden?
Tell us about the companies, countries and transactions involved. Whether you are entering Sweden, reviewing an existing arrangement or responding to a question, we can discuss the work and information needed. Registration is not an order.
If you have any questions before submitting your registration, you are always welcome to contact us.
From understanding the business to explaining the pricing
How we help with your group's transfer pricing
We connect the Swedish operation with the group's transactions, agreements and existing policies, so the analysis reflects how the business actually works.
Functions, assets and risks
We map the Swedish operation's role and how it fits into the group's cross-border business.
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- Related companies, countries and transaction flows
- Who performs the work and makes key decisions
- Assets used and risks managed in each business
- Agreements compared with actual conduct
- … and more
Pricing and comparability
We assess a suitable approach to pricing, based on the transaction and the comparisons available.
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- Selection and review of pricing methods
- Internal or external comparable transactions
- Goods, services, loans and licence arrangements
- Intangible assets and where value is created
- … and more
Documentation and dialogue
We help explain the Swedish position and coordinate the supporting records with your finance team and advisers.
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- Review of group policies and Swedish documentation needs
- Structure for master file and local file information
- Preparation for Swedish Tax Agency questions
- Updates when transactions or operations change
- … and more
A structured approach across borders
How we work
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Understand your transactions
You describe the group, the Swedish activities and the transactions or changes you want to review. We agree an initial scope.
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Review the business and records
We examine the relevant agreements, accounts and roles, identifying the functions, assets and risks and any missing information.
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Assess the pricing approach
We consider the method, available comparisons and supporting analysis, together with your group's existing approach.
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Document and plan the next steps
We agree how the Swedish position should be supported, who will provide the information and what needs follow-up with advisers abroad.
Cross-border transactions with a Swedish connection
Frequently asked questions about transfer pricing
What is transfer pricing?
It concerns the prices and other terms of cross-border transactions between related companies, including goods, services, financing and rights.
What does the arm's length principle mean?
Related parties should agree prices and terms comparable to those independent businesses would accept in similar circumstances. The assessment considers the actual transaction and business activities.
Can we use our group's existing policy in Sweden?
It is a useful starting point. We review how it fits the Swedish operation, its transactions and available records, and identify any local analysis or documentation needed.
Does every company need transfer pricing documentation?
No. Exemptions depend on the applicable rules and group circumstances. Being exempt from formal documentation does not mean that the pricing itself is exempt from the arm's length requirement.
Is there one correct pricing method?
No single method suits every transaction. The choice depends on the activities, terms, evidence and comparability of the transactions being assessed.
Can you help with services, loans and licences?
Yes. We can review a specific arrangement or several flows together, including the roles, agreements and commercial background that support the pricing.
How does this relate to a Swedish branch?
A branch is part of the same legal entity, not a separate subsidiary. Profit attribution to a permanent establishment is therefore a distinct analysis, although arm's length concepts are relevant.
Can you help if the Swedish Tax Agency asks questions?
We help organise the facts and supporting records, review the issue raised and plan the response. Work involving another country can be coordinated with your existing advisers or relevant ETL GLOBAL specialists.
Can an advance agreement or double-taxation procedure be relevant?
Depending on the treaty and facts, an advance pricing agreement (APA) or mutual agreement procedure (MAP) may be relevant. Neither eligibility nor a particular outcome is automatic; Sweden has no unilateral APA programme.
What should we prepare for a first discussion?
Bring a group chart, the countries and entities involved, a short description of the Swedish activities, and the transactions you want to review. Existing agreements, pricing policies, analyses and relevant accounts help us define the next steps.
Want help with your group's transfer pricing?
Register as a new client so we can consider how we can help you. Registration is not an order. If you have any questions before submitting your registration, you are always welcome to contact us.
Swedish expertise with international reach
Local insight for cross-border pricing questions
Transfer pricing often involves more than one country's rules and records. As a member of ETL GLOBAL, Skattepunkten can coordinate with relevant local specialists when an assignment calls for it.
You retain a clear Swedish contact while we work with your finance team and existing advisers on the questions affecting the group's transactions.
Official guidance in English
Relevant links
Explore the Swedish Tax Agency's guidance and the OECD's transfer pricing guidelines.
This page provides general information, not an assessment of a specific transaction. Pricing, documentation, profit attribution and any available procedure depend on the business, the countries involved and the circumstances of the assignment.