Intragroup Services

This chapter considers the transfer prices for intragroup services within an MNE. Firstly, it considers the tests for determining whether chargeable services have been provided by one or more members of an MNE to one or more associated enterprises for transfer pricing purposes. Secondly, if chargeable intragroup services have been provided, it considers the methods for determining an arm’s length consideration for the services. The chapter also considers the circumstances in which tax authorities may provide taxpayers with the option of using a safe harbour for low value-adding services or for minor expenses.

Sustainable Development Goals:

Decent Work and Economic Growth