Transfer pricing of intra-group management services

Question

Has the OECD BEPS project had a significant impact on the transfer pricing of management services and what changes are likely to emerge from the new transfer pricing guidance? What measures should tax professionals be considering as a result?

Answer

Intra-group services are performed for the management and coordination of a group and include the provision of a wide range of services such as legal accounting tax administrative services and business management services. Some tax administrations have considered the charging of management services to be an example of profit shifting if they believe that taxpayers have inflated charges to companies in high tax countries in order to move profits to lower taxed companies. On the other hand services charged at cost or with...