Cross-border, intra-group transactions have become a hot issue in international taxation over the past few years. Not only have multinational entities (MNEs) gained a better understanding of transfer pricing as a tax planning tool, but tax authorities have also increased their focus on the issue and their scrutiny is tougher than ever before.

The Scandinavian authorities have implemented a new transfer pricing documentation regime. In addition, tax authorities have intensified their controls with increased tax investigations through joint audits across the region.