Intra Group Service Agreements

B.4.2.9. An MNE group often centralizes certain business functions within a related company operating as a service provider for the rest of the group or for a subgroup of associated companies, such as a regional subgroup. B, in favor of it. This will centralize a large number of services, including low-quality value-added services. Depending on the case, each related company that benefits from the services of a centralized provider charges a price for the length of services it provides. Economic benefits are necessary if, if not, an associated company is to carry out the activity itself or hire an external service provider. Do not involve the management or control of a significant or significant risk by the service provider and do not lead to a significant risk to the service provider. B.4.1.1. This chapter deals with the transfer prices of intragroup services within an MNE group. First, it reviews the tests to determine whether one or more members of a multinational group have provided transfer pricing services to one or more related companies. Second, when royalty intragroup services have been provided, it examines the methods used to determine the length of services.

This chapter also discusses the circumstances in which tax authorities may offer tax authorities the opportunity to use a shelter for low-value services or for minor expenses. B.4.3.5. There are two general approaches that can be used for service pricing, direct charge and indirect charge. Be consistently determined within an MNE group and a decisive step in the design phase is the development of a formal agreement (service contract) between the company and its customers. This agreement is far from being an ordinary buyer-supplier contract, but aims to regulate interactions between the service company and other companies in the group with respect to price systems, service levels, contractor obligations, bonuses/penalties and associated measurement systems. B.4.1.5. It should be noted that the obligation to pay toll services on the basis of arm length differs from the question of whether such payments are deductible under the national law of the related company receiving the service. Transfer pricing rules require transfer pricing to be paid for paid services. Second, the principles of domestic law are applied to determine whether these payments can be deducted from the related company making the payment to determine its taxable income.