Commentary

B4.146 Transfer pricing—when is a service provided?

Business tax
Business tax | Commentary

B4.146 Transfer pricing—when is a service provided?

Business tax | Commentary

B4.146 Transfer pricing—when is a service provided?

According to the OECD Guidelines1, there are two main issues when analysing intra-group services:

  1.  

    •     whether an intra-group service that should be charged for has been provided, which is outlined below, and

  2.  

    •     what is the arm's length charge for that service (see B4.147)

In determining whether a service has been provided to a related party, it is necessary to look at all surrounding facts and circumstances. It is not possible to establish a set of strict criteria to determine if an activity amounts to a service provided. However, there are generally accepted considerations

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