Cross-Border Intra-Group Services: Lessons from a Peruvian Case Study Involving a Colombian Airline Subsidiary

In the context of international taxation, multinational enterprise (MNE) groups provide a broad spectrum of services to their related entities, ranging from administrative support to technical and commercial services. From a business perspective, these groups aim to ensure that intra-group service provision is carried out efficiently. However, from a practical economic perspective, MNE groups face a variety of challenges in reconciling this objective. Drawing on a Peruvian transfer pricing case involving a Colombian airline subsidiary, in this article the author examines the principal considerations and implications that must be taken into account when managing cross-border intra-group services.