Transfer Pricing Aspects of Intra-Group Services: What Are the Open Issues and What Can Be Improved?

The intercompany provision of services is one of the most common transactions among entities belonging to the same multinational group and it is regularly scrutinized by the tax authorities. This article looks into the international guidance on intra-group services, focusing on all the unclear and weak aspects that need to be clarified and improved in order to reduce the tax authorities’ challenges and to provide the taxpayers with more certainty.