Transfer pricing documentation differences in Finland and China - Case company study

Abstract

This Master’s Thesis deals with the topic of transfer pricing documentation in Finland and China. The goal of the research is to find what kind of differences exist in a single case company’s transfer pricing documentation when following Chinese or Finnish transfer pricing regulations. The study is carried out as a case study research. The theoretical framework consists of information from different transfer pricing topics and transfer pricing documentation regulations in China and Finland. The main research material was the case company’s transfer pricing documents with the support of open discus-sion with one of the case company’s employees. The study compared the 2009 and 2010 documents. The 2009 document was done based on the Finnish method while the 2010 document was based on the Chinese documentation principles. The conclusion made is that the content of the documents was heavily similar, while the main differences come in the way the content is presented and the level of detail used in the documents.