The Norwegian tax authorities have published a report (in Norwegian) describing their focus on transfer pricing for the fiscal year 2009. The interest in the report lies in the overview of their efforts, particularly in audits in FY09, the results of these efforts and their key focus areas in FY2010.

The tax effect of all transfer pricing related reassessments made for 2009 is about NKr2.5 billion ($427 million). Although some of these reassessments are not final, this gives some idea of the extent of the focus on transfer pricing by the tax authorities. The final adjustments amount to about NKr198 million in increased taxes.

The report also provides a summary of nine different court cases from 2009 relating to transfer pricing issues, of which six decisions are from the lower courts and three decisions are from the appeal courts. The subjects for the court cases range from the allocation of income, between headquarters and branch (Dell), cash pooling interest rates (ConocoPhilips), sale of shares (Dynea, Tandberg), charges for services (Enterprise), and loss on investments in a foreign subsidiary.