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Transfer Pricing Alert

Understanding Intra-Group Services and Compliance

Intra-group services are essential activities provided by one entity within a business group that benefit other members. These services can range from management and administration to technical and support services. Recognizing and documenting these transactions is crucial for compliance and ensuring economic benefits.

Key points

  • Definition and Types: Intra-group services include management, administration, technical, support, purchasing, marketing, distribution, and other commercial services related to the group's business.
  • Economic Benefit: The existence of intra-group services is recognized if they provide economic benefit or commercial value, such as increasing profit or improving efficiency by reducing operating costs.
  • Arm's Length Principle: To determine the arm's length payment for intra-group services, consider whether an independent party in comparable conditions would pay for the service or perform it in-house.
  • Service Categories:

(Revenue Audit Memorandum Order No. 1-2019 and internationally recognized transfer pricing guidelines)

Ensure that all intra-group services are properly documented and comply with the arm's length principle. Accurate documentation not only supports compliance but also enhances the economic efficiency of your business operations. Stay proactive in managing and recording intra-group services to maintain transparency and integrity in your business practices.

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