Secondary Transfer Pricing Adjustments: Interpretation Challenges within the EU and International Perspectives

Sammanfattning: This master thesis elaborates on the issues of the secondary transfer pricing adjustments that are common yet not regulated in an efficient manner by the states. The core problem of the double taxation issues to follow is the unwillingness of the states to accept the administrative tax decisions of each other in such sensitive fields as transfer pricing. Even though the primary and correlative transfer pricing adjustments are addressed within the framework of the international tax instruments (such as the OECD MC), no common ground is developed with respect to the secondary transfer pricing adjustments. This, in turn, contributes to the development of the interpretation issues in terms of the payments underlying the secondary transactions (quasi-transactions to arise after the secondary transfer pricing adjustment was made).