Considerations on Icelandic Transfer Pricing Rules in Light of First District Court Ruling in Transfer Pricing Case

This article analyses Iceland’s first court ruling on transfer pricing, delivered by the District Court of Reykjavík. The case highlights the exceptionally high bar set for comparability analyses and emphasizes that the burden of proof lies with the taxpayer where documentation is not considered adequate. Notably, the Icelandic tax authorities maintain that it is not their role to develop or justify transfer pricing policies on behalf of taxpayers, reinforcing the need for robust, contemporaneous documentation and a defensible pricing methodology.

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Publication Details

Journal
International Transfer Pricing Journal
Published
2025-06-11
DOI
https://doi.org/10.59403/1bp82d7
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

Considerations on Icelandic Transfer Pricing Rules in Light of First District Court Ruling in Transfer Pricing Case

Vigdis Sigurvaldadottir
International Transfer Pricing Journal
Corporate Taxation and Avoidance
article

Considerations on Icelandic Transfer Pricing Rules in Light of First District Court Ruling in Transfer Pricing Case

Vigdis Sigurvaldadottir
article en

Abstract

This article analyses Iceland’s first court ruling on transfer pricing, delivered by the District Court of Reykjavík. The case highlights the exceptionally high bar set for comparability analyses and emphasizes that the burden of proof lies with the taxpayer where documentation is not considered adequate. Notably, the Icelandic tax authorities maintain that it is not their role to develop or justify transfer pricing policies on behalf of taxpayers, reinforcing the need for robust, contemporaneous documentation and a defensible pricing methodology.

International Transfer Pricing JournalVol. 32(4)
Openalex Percentile: Top 81%
Corporate Taxation and Avoidance
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Considerations on Icelandic Transfer Pricing Rules in Light of First District Court Ruling in Transfer Pricing Case — Vigdis Sigurvaldadottir · International Transfer Pricing Journal (2025) | TGRS Research Map | TGRS