Transfer Mispricing in the Oil Industry: How important has transfer mispricing been in the construction of the current Norwegian tax regime for the petroleum industry?

Abstract

In this thesis I investigate how important transfer mispricing has been in the construction of the current Norwegian petroleum tax regime. Transfer mispricing has real world consequences, and recent studies (Pak, 2012, p. 36) show that in the time span 2000-2010 over $110 billion have disappeared through mispricing of crude oil in the EU and the US. By doing a case study of the Norwegian case more information might uncover about transfer mispricing. I create a typology with six considerations, and test how important each of these have been in eight propositions concerning changes to the petroleum taxation. My findings show that transfer mispricing is not the most important consideration when changes have been made to the Norwegian tax regime for petroleum. I find that efficiency and fiscal considerations are the most important considerations over time. But transfer mispricing is an important consideration for tax officials when they make changes to the petroleum taxation system, in the sense that transfer mispricing is a problem that is constant over time and the officials have created an approach to the arms length principle, the norm price system, which is designed to control transactions between companies operating on the Norwegian shelf and stop transfer mispricing from happening.