This paper presents a study of the Swedish public service television broadcaster - Sveriges Televisions (SVT) Transfer Pricing model. The aim of the thesis is to examine the motives for using Transfer Pricing from a theoretical perspective and if SVT?s Transfer Pricing model fulfils these motives. We will also examine any potential managerial problems the existing transfer-pricing model might cause and discuss how these could be solved. We have in our study found that the main motive for using Transfer Pricing within SVT is to allocate internal resources as efficiently as possible.

This paper presents a study of Scandinavian Airlines? (SAS) frequent flyer program, EuroBonus. The study describes the Transfer Pricing of award seats between EuroBonus and the airlines within SAS. Furthermore, it aims to determine what effects market-based Transfer Pricing would have on EuroBonus, the airlines within SAS and consequently on the SAS Group. We have found that the existing Transfer Pricing does not provide incentives for the airlines within SAS to satisfy EuroBonus? demand for award seats.

Throughout this thesis three main factors have been identified that can be out of significance for Transfer Pricing in multinational companies if the proposal for Home State Taxation is adopted. These factors are rules for calculation of the tax base, rules for dividing costs over periods and the tax rate. The formula for sharing profits will also become a factor that can have an impact on the European companies'incentives for Transfer Pricing interacting with above-mentioned factors. The effects of Transfer Pricing aiming at reducing the total amount of the taxation burden for a group of companies will be strongly reduced in the future if the proposal is adopted. Incentives for Transfer Pricing will loose importance, though not disappear altogether.

Background: When companies decentralize their operations into profit centers, Transfer Pricing often becomes an integral part in intracompany trade. A profit center may affect both revenues and costs and seek to maximize profit. Transfer Pricing is a complex subject because it is affected by a large number of factors including the profit centers will to generate profits. This leads us to the subject of decision-making in a Transfer Pricing-systems. On what grounds are decisions made? Are Transfer Pricing purposes, factors and interests taken into consideration? What type of information is used in such decisions, how is the transfer price issue perceived and how is it used?Aim: The purpose of this thesis is to analyze which type of information that is makes up transfer prices, how the transfer price is perceived by different parties and how it is used for decision-making.Completion: A qualitative study has been performed with current theory as a starting point.

As the globalization of companies increases day by day, the need for a clear and comprehensible legislation to overcome the problems with Transfer Pricing transactions increases as well. Incorrect pricing in Transfer Pricing situations between companies with close economic ties to each other makes countries risk parts of their taxation income.Swedish legislation uses the internationally accepted arm?s length principle to regulate the Transfer Pricing transactions. Through the correction rule, the rule is upheld that the pricing between two companies with close economic ties to each other must apply to the same conditions as it would have been if it was between two companies without close economic ties to each other.To ensure that enough material is provided to base the assumption whether or not the correction rule has been followed or not, Swedish legislation provides a number of paragraphs to regulate the matter. The legislation is spread all over and is hard to interpret.

As the globalization progresses, the matters of Transfer Pricing have become essential to multinational enterprises and tax administrations. For states it is important that the Transfer Pricing is correct to defend their tax base. Incorrect Transfer Pricing can also have dire effect on the enterprises. They run the risk of both double taxation and tax penalties. Some of the most difficult assets to put a transfer price on are intangibles.

Transfer Pricing has attracted considerable interest among tax authorities in recent years. One of the reasons for this is that various countries have now begun to protect their own tax bases to a greater extent than they did in the past. Sweden has introduced a law on the documentation on the grounds that the tax office to review the pricing of transactions that occur within multinational corporations. The purpose of the law is that companies should apply a Transfer Pricing that meet arm's length principle, which means that internal pricing reflects market prices. The EU Commission has, together with the EU member states formed a Forum, the EU Joint Transfer Pricing Forum (JTPF), since cross-border trade within groups constitute a threat to the internal market. The Forum has drawn up a code of conduct which includes a model of documentation.

The arm?s length principle has existed in Swedish law since 1928 but has previously been given little attention. In 2007, documentation requirements were introduced, and the government began to do tax audits regarding Transfer Pricing. This thesis examines how the documentation requirements and tax audits affect the application of the arm's length principle. The research consists of nine interviews with a total of ten people at the tax authority (Skatteverket) and audit- and consulting agencies. The results of the interviews are analyzed using the agency theory. Many companies are risk averse and prefer having correct Transfer Pricing instead of taking on challenging strategies that can be risky in case of an investigation by Skatteverket.

The arm?s length principle has existed in Swedish law since 1928 but has previously been given little attention. In 2007, documentation requirements were introduced, and the government began to do tax audits regarding Transfer Pricing. This thesis examines how the documentation requirements and tax audits affect the application of the arm's length principle. The research consists of nine interviews with a total of ten people at the tax authority (Skatteverket) and audit- and consulting agencies. The results of the interviews are analyzed using the agency theory. Many companies are risk averse and prefer having correct Transfer Pricing instead of taking on challenging strategies that can be risky in case of an investigation by Skatteverket.

According to the arm?s length principle, transactions between associated multinational en-terprises (MNE) shall be based on the same conditions as transactions between unrelated parties. This means that intra-group prices on cross-boarding transactions must be at arm?s length range and consistent with conditions in the open market. The arm?s length principle is expressed in article 9.1 of the OECD Model Tax Convention and Chapter 14 section 19 of the Swedish Income Tax Act.When Transfer Pricing between associated MNEs is not reflecting the arm?s length princi-ple, states face the possibility of losing tax revenue.

A study has been conducted on how organizations in Sweden administer costs of facilities management services internally. There are three main theoretical methods for administering costs. In the first method, costs are maintained on a central level; in the second method, costs are allocated and in the third method, internal Transfer Pricing is used. The aim of the study is to identify which methods are applied in practice, to evaluate whether the methods fulfill their intended purposes and to study the relationship between the methods used and the cost level of facilites management services. In practice, a large diversity of methods are used for facilities management costs.

Due to the growth of multinational concerns during the last decades, with large parts of international trade involving such corporations, the field of Transfer Pricing, including financial transactions such as internal loans, have received a great deal of attention in tax legislation. The internationally accepted foundation for Transfer Pricing is the so called Arm's length principle, expressed in Swedish law through the "Korrigeringsregeln". In the Diligentia court case, the concepts of transparency and control were given a crucial role in the calculation of an Arm's length's price of interest rates. The Swedish tax agency interpreted the ruling in that case as if a parent company always can be assumed to enjoy sufficient transparency and control to reduce the risk on their debt obligations. A great deal of uncertainty therefore surrounded their position and to what extent the Diligentia-ruling could be cited as precedent.

Vårt syftet med C-uppsatsen är att ur en pedagogisk synvinkel få en inblick i pedagogers uppfattning om sin kompetens i hur man möter barn i sorg. För att ta reda på detta har vi intervjuat sex pedagoger i södra Sverige. Vi har använt oss av en kvalitativ metod med semistrukturerade intervjuer. Vi har bearbetat litteratur som belyser pedagogens handlande och skolans roll. Vi har även behandlat litteratur som tar upp vilka olika krisfaser man går igenom när man har drabbats av en traumatisk händelse.

Purpose: The purpose of this master thesis is to investigate how a pricing capability can be developed on a general as well as on a practical level in an industrial company working on the international business-to-business market. Methodology: We have conducted a case study of the work on pricing at Triton. After mapping the events we have evaluated the results. We have conducted interviews with people with information concerning Tritons work in the Pricing area. Theoretical perspectives: The theory includes organization and structure, pricing for the market with emphasis on transactions and theories on how to understand the customer.

Syfte:- Att undersöka om OECD:s riktlinjer är vedertagna hos de granskade koncernerna och beskriva vilka internprissättningsmodeller de använder sig av.- Att beskriva vilka effekter de undersökta koncernerna försöker uppnå med sin internprissättning.- Att undersöka vilken vikt skatteaspekten har för dessa koncerner vid sin internprissättning.- Att undersöka hur dessa koncerner dokumenterar sin interprissättning och vilka påföljder de nya dokumentationskraven kommer att få för dem..