Article
The Scope Of The Swedish Transfer Pricing Correction Rule
The Swedish Supreme Administrative Court ruled in favor of Kubikenborg Aluminium AB in a landmark transfer pricing case, setting aside a SEK 211 million adjustment related to an electricity contract termination and shareholder contribution. The court held that the arm's length assessment must consider the overall group arrangements, finding that the tolling agreement structure meant the electricity contract risk was borne by related entities rather than constituting an income transfer from the Swedish compa
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