OECD Intra-Group Services - Understanding the Proposed New Chapter VII Guidance

Introduction

Intra-group services are a common source of transfer pricing risk for multinational businesses, particularly where management charges, centralised services and cost allocations need to be demonstrated to provide an economic or commercial benefit to the recipient.

The OECD has proposed significant revisions to Chapter VII of its Transfer Pricing Guidelines, seeking to modernise and clarify the guidance on intra-group services and provide additional practical examples.

Delivered by expert speaker Rafaela Oplopoiou-Chapman, this new live and interactive session will examine the proposed revised guidance and explain how the principles should be applied to common intra-group service arrangements in practice.

It is designed for tax advisers, accountants and in-house tax and finance professionals responsible for establishing, reviewing or documenting intra-group service charges.

What You Will Learn

This live and interactive session will cover the following:

• Identifying intra-group services
• What constitutes an intra-group service?
• Applying the benefit test
• Economic or commercial value
• Services that an independent enterprise would pay for
• Duplicate services
• Incidental benefits
• Shareholder activities
• What's changing under the proposed Chapter VII guidance?
• Why the OECD is revising Chapter VII
• Key proposed changes and clarifications
• Alignment with Chapters I, II and III
• Accurate delineation of intra-group services
• New and revised practical examples
• What businesses and advisers should be reviewing now
• Pricing intra-group services
• Direct and indirect charging methods
• Identifying the appropriate cost base
• Cost allocation keys
• Determining an arm's length mark-up
• Pass-through costs
• Applying transfer pricing methods to service arrangements
• Low value-adding intra-group services
• Identifying qualifying services
• Simplified approach
• Cost pools
• Allocation methodologies
• Mark-ups
• Documentation requirements
• Common areas of uncertainty
• Management charges and centralised services
• Head office and regional management charges
• IT, HR, finance and administrative services
• Shared service centres
• Distinguishing shareholder costs from chargeable services
• Demonstrating that the recipient has received a benefit
• Documentation and practical risk management
• What evidence should be retained?
• Intercompany service agreements
• Demonstrating services have actually been provided
• Supporting allocation keys and mark-ups
• Common weaknesses in intra-group services documentation
• Practical case study

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.