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Dokumentationsskyldighet vid internprissättning: konsekvenser för Sandvik AB och Scania AB
Örebro University, Swedish Business School at Örebro University.
Örebro University, Swedish Business School at Örebro University.
2008 (Swedish)Independent thesis Advanced level (degree of Master (One Year)), 10 credits / 15 HE creditsStudent thesis
Abstract [en]

Abstract

A large part of the world trade takes place within international corporate groups. These groups need to take control not only over external but also internal transactions. Transfer pricing affects companies handling of taxes and in many states problems have been noticed in the establishment of these prices. A new legislation on the obligation to document transfer pricing in Sweden was introduced on January 1 2007. This obligation to document means that the Swedish enterprises must document the corporate group transactions to be able to prove that they use market price.

The purpose of this thesis is to study the consequences that Sandvik AB and Scania AB have gained because of this obligation to document and how the transfer pricing in these companies has been affected. The consequences have been studied through analyzing interviews with representatives for these companies in terms of transaction costs. Furthermore the companies reaction against the obligation to document, have been analyzed through the five strategic responses presented by Christine Oliver (1991). The thesis also discusses the phenomenon transfer pricing and the theory chapter is based on the concept of transaction costs.

To be able to answer our research questions and fulfill the purpose of the thesis, semi-structured interviews were carried out at Sandvik AB´s and Scania AB´s head offices. From these interviews we could see that the establishment of the documentation is problematic, because it hasn´t yet been clarified what the documentation should include. The consequences that Sandvik AB for example has gained are the need to revalue their intellectual property and because of that they have obtained excess work. They have also hired consultants so that the documentation can be authorized. The consequences in Scania AB among other things are that they have employed an expert in the area. In addition to these consequences both companies have gained a more obvious administrative order of their activities.

From the respondents we have perceived the reactions on the obligation to document as diversified between the companies. At Sandvik AB they comply with the obligation to document and try to pursue the recommendations. Scania AB on the other hand tries to pursue the obligation to document in balancing the already existing transfer pricing methods with the recommendations. A larger extent of accommodation to the obligation to document is therefore shown in Sandvik AB while Scania AB shows more of a compromise with the recommendations when they establish their documentation.

Place, publisher, year, edition, pages
2008. , 48 p.
Keyword [sv]
Internprissättning, Dokumentationsskyldighet
National Category
Business Administration
Identifiers
URN: urn:nbn:se:oru:diva-4892ISRN: ORU-HHS/FEK-AG-2009/0002--SEOAI: oai:DiVA.org:oru-4892DiVA: diva2:139194
Presentation
(English)
Uppsok
Social and Behavioural Science, Law
Supervisors
Examiners
Available from: 2009-10-06 Created: 2009-10-06Bibliographically approved

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CiteExportLink to record
Permanent link

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Cite
Citation style
  • apa
  • harvard1
  • ieee
  • modern-language-association-8th-edition
  • vancouver
  • Other style
More styles
Language
  • de-DE
  • en-GB
  • en-US
  • fi-FI
  • nn-NO
  • nn-NB
  • sv-SE
  • Other locale
More languages
Output format
  • html
  • text
  • asciidoc
  • rtf