On 29 August 2018, the Swedish Tax Agency (Skatteverket) has updated its transfer pricing guidance to incorporate the OECD guidance on the application of the transactional profit split method, which was revised as part of the work for BEPS Action 10.
The update notes that the revised section of the guidance is a clarification of how the profit split method is to be applied and there has been no change in the arm’s length principle as such. The new guidance can, therefore, be applied both forwards and backwards.
