The main part of the article is devoted to a critical analysis of the optional transfer pricing provisions in the EC VAT Directive in the light of the principle of fiscal neutrality. As an integrated part of this analysis, the VAT transfer pricing regime is considered in the light of the well-known principles for transfer pricing in the area of income tax law, as set out in Art. 9 of the OECD Model Tax Convention. The last part of the article contains a brief discussion of to which extent it is desirable to harmonize the two tax systems´ transfer pricing rules.
Yearbook for Nordic Tax Research 2011: Taxation on Intangible Assets, 2011, p. 209-229