Betydelsen av ett moderbolags insyn och kontroll över sitt dotterbolag vid prissättning av koncerninterna lån
Transfer pricing including internal loans have increased in recent years, making it easier for companies to minimize their taxable income. After the Swedish court case Diligentia, there have been discussions regarding the influence of a parent company's transparency and control of the subsidiary with regards to the interest rates on internal loans. In court cases that followed Diligentia, the Swedish Tax Agency argued that a parent company always could be assumed to have sufficient transparency and control of the operations in the subsidiary, and therefore reduce the risk on their debt obligations. This thesis seeks to analyze the effects of the transparency and control a parent company has with regards to interest rates on internal loans. The analysis is conducted by analyzing court cases similar to Diligentia. We find support that an assessment of the debt obligation agreements should be done on a case-to-case basis as they have an impact on the parent company's transparency and control. Furthermore we find support that there should be an assessment of the effect of a parent company's partially transparency and control on the interest rate.