Proposed transfer pricing reporting and documentation requirements

Following the introduction of documentation rules by an increasing number of countries, the Norwegian Ministry of Finance has released a White Paper on reporting and documentation requirements for taxpayers with controlled domestic and cross-border transactions. The proposal on the documentation requirements is aligned with the OECD Transfer Pricing Guidelines and the EU Code of Conduct on Transfer Pricing Documentation for Associated Enterprises in the European Union. In addition, the position of the OECD Transfer Pricing Guidelines as an authority on the application of the arm's length principle is strengthened, and EEA/EU law impacts both the documentation requirements and the burden of proof.