Commentary

B4.145 Transfer pricing and services

Business tax
Business tax | Commentary

B4.145 Transfer pricing and services

Business tax | Commentary

B4.145 Transfer pricing and services

Intra-group services commonly attract the attention of revenue authorities. This is perhaps at least in part because specific industry knowledge is not always required to examine intra-group services and a relatively large amount of comparable data is available.

Any company providing services to its affiliates needs to make a concerted effort to ensure that the services are identified, a charge is made, the charge is arm's length, and that adequate documentation is kept. The issues surrounding intra-group services has become more important as growing numbers of companies rationalise management functions in an effort to reduce costs and increase shareholder value.

Intra-group services can encompass a wide array of services including administrative, technical, financial, and commercial services. The OECD Guidelines

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