Intra-Group Services: Issues, Solutions and Issues in Solutions

This article discusses the major issues faced by both taxpayers and tax authorities as regards intra-group service transactions, and analyses in detail the various simplification measures taken by tax administrations of various countries to resolve some of these issues for the taxpayers. The issues can be broadly classified as either the question whether intra-group services have indeed been provided, or, if that is the case, what should be the arm’s length price or charge for such services.