Swedish court rules on hindsight in arm’s-length pricing

Lena Angvik

December 28, 2017

A Swedish court has ruled on timelines for information used in benchmarking searches in a case involving The Absolut Company, which produces Absolut Vodka. The court concluded, supported by the OECD TP Guidelines, that looking at data from years after the year under review would constitute hindsight and would not be accepted.

Unlock this article.

The content you are trying to view is exclusive to our subscribers.

To unlock this article:

Take a Free Trial or Login

More from across our site

Protester carries a flag during a demonstration against Presiden

Brazil has 120 days to settle TP reform

Lawmakers have up to 120 days to decide the future of Brazil’s unique transfer pricing rules, but many taxpayers are wary of radical change.

Josh White, February 03, 2023

This week in tax: Shell’s profits spark tax calls

Shell reports profits of £32.2 billion, prompting calls for higher taxes on energy companies, while the IMF has warned Australia to raise taxes to sustain public spending.

Josh White, February 03, 2023

Viersen, Germany - January 9. 2022: Closeup of mobile phone with

OECD releases final technical guidance for global minimum tax

Governments now have the final OECD guidance on how to implement the 15% global minimum corporate tax rate.

Josh White, February 02, 2023

Infosys acknowledges £20m tax dispute with HMRC

The Indian company, which is contesting the bill, has a family connection to UK Prime Minister Rishi Sunak – whose government has just been hit by a tax scandal.

Josh White, February 01, 2023

Marina Bay Sands and ArtScience Museum in Singapore after sunset

This month in indirect tax: GST reform in Malaysia; VAT updates in UK, Italy, Ukraine

Developments included calls for tax reform in Malaysia and the US, concerns about the level of the VAT threshold in the UK, Ukraine’s preparations for EU accession, and more.

James Nurton, February 01, 2023

Korean companies stay cautious despite pillar two push

A steady stream of countries has announced steps towards implementing pillar two, but Korea has got there first. Ralph Cunningham finds out what tax executives should do next.

Ralph Cunningham, January 30, 2023

Analysis: NGOs and businesses find common ground on BEFIT

The BEPS Monitoring Group has found a rare point of agreement with business bodies advocating an EU-wide one-stop-shop for compliance under BEFIT.

Josh White, January 27, 2023

Australia’s DPT has been dismissed by many groups as simply a threat used to ensure proper TP analysis

This week in tax: PwC partner banned in Australia over tax leaks

Former PwC partner Peter-John Collins has been banned from serving as a tax agent in Australia, while Brazil reports its best-ever year of tax collection on record.

Josh White, January 27, 2023

Business groups raise TP concerns over BEFIT

Industry groups are concerned about the shift away from the ALP towards formulary apportionment as part of a common consolidated corporate tax base across the EU.

Josh White, January 26, 2023