Intra-group services feature in most multinational groups and are a common transaction type in transfer pricing policies. Charging for services is crucial to get right, as tax authorities will often raise questions focused on whether there should be a deduction in a territory. Understanding the benefit created by the services is a key step, together with understanding how best to allocate costs, set a mark up and identify what should not be charged. Good documentation is important and groups may be able to take advantage of the new OECD simplified approach when supporting the charges made.
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