Transfer pricing in Sweden at a glance
|Are there specific transfer pricing regulations?||Yes|
|Submission deadline upon request||30 days|
|Annual update required||No|
|Official language requirements||Swedish, Danish, Norwegian and English|
|Potential impact of penalties||N/A|
Swedish tax law
Rules for transfer pricing in Sweden are based upon:
- Income Tax Act sections 14:19-20
- Tax Procedures Act 39:15-16
- Advanced Pricing Agreement Act
Sweden follows the OECD Transfer Pricing Guidelines.
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 Sweden suggest the most appropriate method should be used. In any case are the traditional methods preferred over the transactional methods.
Information that should be included in the documentation:
- A description of the company, organization and business operations
- Information regarding the characteristics and scope of the transactions
- A functional analysis
- A description of the chosen pricing method
- A comparability analysis
Requirements to prepare documentation annually
Rules for transfer pricing in Sweden do not provide an obligation to prepare transfer pricing documentation annually.
Submission deadline upon request by tax authorities
Upon a request of the tax authorities, a taxpayer a taxpayer has 30 days to submit the documentation.
Advance Pricing Agreements
Since 2010 it is possible to obtain bilateral or multilateral Advance Pricing Agreement (APA) in Sweden.
The term for which an APA is agreed upon is generally three to five years.
Rules for transfer pricing in Sweden do not provide for specific transfer pricing penalties, meaning that ordinary penalties apply.