Cost Allocations for Intra-Group Services Based on the 2017 OECD Guidelines

Intra-group services in multinational enterprises (MNEs) continue to be scrutinized by tax authorities during transfer pricing audits. While many MNEs have significant experience with intra-group services, some continue to struggle with managing their intra-group service cost allocations in a compliant and transparent manner. In this article, an applied theoretical model is proposed that MNEs can use when (re)designing their cost accounting practices for intra-group services. The model is based on the 2017 OECD Guidelines, including the low value-adding service concept introduced in the 2017 revision of chapter VII of the OECD Guidelines.