Introduction
In Norway, the arm’s-length standard for related party transactions is incorporated
into the General Tax Act (GTA) 1999 Section 13-1. The GTA Section 13-1 (4) makes
reference to the Organisation for Economic Co-operation and Development (OECD)
Transfer Pricing Guidelines (TPG) and state that the TPG ‘shall be taken into account’.
The reference is to the guidance on the arm’s-length principle and the transfer pricing
methods. It is also assumed that the reference includes the OECD guidance on business
restructuring. Transfer pricing documentation and reporting requirements became
effective from fiscal year 2008.
The Norwegian tax authorities consider transf