Arntzen de Besche uses its transfer pricing practice to assist clients with complex cross-border restructuring, reorganisations and transactions, including advising on MAPs discussions. It focuses on providing advice to the oil and gas, shipping, real estate and financial sectors. Anders Heieren is the lead partner of the department.
The team has worked with Shearwater GeoServices on its publicised acquisition of WesternGeco's marine seismic department, including all vessels, streamers and technology. The $600 million acquisition and three-way share split required a complex structure for the transaction, as well as a TP policy adjustment following the acquisition.
Norwegian law firm BAHR is one of the leading law firms offering transfer pricing advice. The TP department advises numerous companies on disputes and negotiations with the Norwegian authorities, as well as assisting with TP policy restructuring and advice on M&A. The team includes key partners, Jan Jansen and Joachim Bjerke.
The firm has assisted a number of oil companies following the ruling of the Norwegian Tax Office on the deductibility of costs associated with participation in government-organised R&D projects. The Office's judgment that the oil companies should invoice its related oil companies in other jurisdictions requires a detailed re-evaluation and adjustment of the transfer pricing policies for the clients of the firm.
Deloitte Norway has a large, multidisciplined transfer pricing team, with offices across Norway and a strong affiliation with other transfer pricing teams within the Deloitte North West Europe team. It offers all advisory and economic transfer pricing services to clients from all sectors. It is also constantly strengthening its transfer pricing technology offering. Deloitte has a global relationship with Oracle and Thomson Reuters to complement the firm’s own developed software for the automation of transfer pricing. Hans Martin Jørgensen is the head of the practice. Marius Basteviken is the other notable partner in the Nordic transfer pricing team. Both are dual-trained economists and lawyers, exemplifying the multifaceted nature of the practice.
The firm recently advised a Norwegian technology MNE in a review of its transfer pricing model following its acquisition by a private equity firm, in order to ensure compliance under the BEPS principles. The review included economic analysis and modeling, benchmarking, analysis of intercompany financing, advice on the group’s principle structure and assistance with policy implementation and transfer pricing documentation.
The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness Platform, Solutions & Intelligence and operational transfer pricing practice serving clients’ needs across all jurisdictions.
Led by well-recognised, Oslo-based partner Sveinung Baumann-Larsen, the operational transfer pricing team brings together multi-disciplinary experience and resources focusing on IT, accounting, and tax from the entire region to bring to bear in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals.
KPMG's Norway transfer pricing department has abilities in all fiscal, legal and advisory services. The department operates in all industry sectors, but has a very strong connection with a collection of large oil, gas and shipping clients. It includes partners Per Daniel Nyberg, Svein Andresen and Jan Samuelsen. Andresen is chairman of the board of KPMG Law and Samuelsen is a member of the tax committee of the Norwegian Oil and Gas Association.
The firm is currently advising an offshore fibre telecom provider in the preparation of BEPS-compliant documentation for 2015-2017, as well as advice on the operational transfer pricing of the client. It is assisting the same client with a matter relating to the divestment of the current private equity owner of the client.
PwC offers a relatively small transfer pricing department in Norway, but through its experts in domestically and internationally it is able to offer clients a full suite of transfer pricing advice and analysis. It also provides representation for clients undergoing transfer pricing audits, as well as support in discussions with the relevant authorities in APAs/MAPs negotiations. Director Morten Beck is a senior transfer pricing practitioner in Norway, with expertise in international tax as well as transfer pricing.
The firm currently assists Transocean on the transfer pricing structure and due diligence necessary to employ during its acquisition of Songa Offshore and Ocean Rig. The ongoing work includes the design and application of structures and policies attaining to the integration of Songa and Ocean Rig into the Transocean group.
Thommessen has a sizeable team of professionals with expertise within transfer pricing and business restructuring. It focuses on providing assistance to clients undergoing transfer disputes, such as audits and litigation, or assisting clients with MAPs/APAs discussions with the relevant authorities. Senior transfer pricing practitioners within the firm include partner Hanne Skaarberg Holen and department head Finn Backer-Grøndahl.
The firm recently represented Skangas LNG Production in its District Court case regarding its right to reduce the rate of excise duties on electrical power purchases through business coding. It also represented Orange Business Services in a transfer pricing controversy, regarding the profit split method employed by Orange Business Services on a global level.