On 22 December 2015, the Swedish tax authority published a notice in its online transfer pricing guidance (Swedish language) that it will follow the OECD guidelines developed as part of Action 8-10 of the OECD BEPS Project as included in the final report Aligning Transfer Pricing Outcomes with Value Creation. These guidelines cover:
- Guidance for Applying the Arm's Length Principle;
- Commodity Transactions;
- Guidance on the Transactional Profit Split Method;
- Intangibles;
- Low Value-adding Intr…