Permanent establishment – Intragroup supply of services

Documentation of low value-adding intra-group services

Guidelines on low-value-adding intra-group services

Tags: Intragroup supply of services, Permanent establishment

Transfer pricing assessment of intragroup services and financing

internal provision of service (administrative tasks concerning your job service and employment, IT services, etc.);

How will the arm’s length principle be applied for low value-adding intra-group services?

Almost 75% of available simplification measures are directed to SMEs, small transactions and low value added intra-group services,

Any Ennismore group company providing intragroup services, including marketing, finance, IT, system administration, HR services and leadership reporting.

November 3, 2014 Discussion Draft on low-value-adding intra-group services (IGS Draft)

INDIRECT-CHARGE METHOD : A method of charging for intra-group services based upon cost allocation and apportionment methods.

INDIRECT-CHARGE METHOD -- A method of charging for intra-group services based upon cost allocation and apportionment methods.

The SECO has now formalized its former practice in a written directive, with the clear intention to make intragroup secondments generally subject to a permit restriction.

Discussion Draft of the Proposed Modifications to Chapter VII of the Transfer Pricing Guidelines Relating to Low Value-Adding Intra-Group Services