The green transition is transforming global energy markets, yet when it comes to transfer pricing for large-scale renewable projects, there is still no clear global best practice. This creates complexity for businesses and tax administrations alike.

In a Tax Notes International Special Report, our colleagues Karl Berlin, Katja Dyppel Weber and Louise Blichfeldt Fjord examine the transfer pricing challenges across the different phases of renewable generation projects. The OECD’s classic FAR analysis remains the cornerstone, but it must be applied with a clear understanding of the industry’s unique characteristics: high capital intensity, long lead times, phases that differ in functional intensity, assets as the primary value driver, and location factors such as physical conditions and access to state aid.

Our aim is to contribute to shaping best practice in this emerging field and to promote a balanced, level-headed approach that respects these fundamentals.

Read the full article here: https://lnkd.in/dHsykHey