Transfer pricing in Iceland

Transfer pricing in Iceland at a glance

Regulation Type OECD
Are there specific transfer pricing regulations? No
Submission deadline N/A
Submission deadline upon request N/A
Annual update required N/A
Official language requirements N/A
Potential impact of penalties N/A

 

Icelandic tax law

Rules for transfer pricing in COUNTRY are based upon:

  • Income Tax, article 57 of Act No. 90/2003
  • Law no. 142/2013 of December 23, 2013

OECD

Iceland, as an OECD member, follows the OECD Transfer Pricing Guidelines. However, in Icelandic tax law no specific reference is made to the OECE Guidelines.

Methods

Accepted methods

Accepted methods are:

  • The comparable uncontrolled price method
  • The resale price method
  • The cost plus method
  • The profit split method
  • The transactional net margin method

Priority of methods

Rules for transfer pricing in Iceland do not specify any regulations about the transfer pricing methods. Therefore it is considered that all of the methods above are excepted, since these methods are accepted by the OECD Guidelines.

Associated enterprises

Rules for transfer pricing in Iceland consider enterprises related when:

  • Part of a consolidated group, or are under direct or indirect majority ownership or managerial control of two or more enterprises within a consolidation
  • Under majority ownership of one enterprise by another, in the aggregate both directly and indirectly
  • Directly or indirectly under majority ownership or managerial control of individuals related by marriage, family ties, or financial ties

Documentation requirements

Information that should be included in the documentation:

Rules for transfer pricing in Iceland prescribe that taxpayers with a total revenue or assets as of the beginning of the year or at year-end exceeding 1,000 million ISK (approximately U.S. $8.7 million) must maintain transfer pricing documentation.

  • The nature and extent of transactions with related parties (including subsidiaries or permanent establishments)
  • The nature of the related-party relationship
  • The basis for the price(s) asserted

The document requirement also refers to the OECD transfer pricing guidelines.

Language 

Not applicable.

Requirements to prepare documentation annually

Not applicable.

Submission deadline upon request by tax authorities

Not applicable.

Advance Pricing Agreements

General

Not applicable.

Terms

Not applicable.

Penalties

Not applicable.

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