Transfer Pricing and Intra-Group Services

Introduction to Transfer Pricing and Intra-Group Services

• Importance of intra-group services for both tax administrations and MNEs
• Policy framework in place: perspective of OECD/UN/EU and jurisdictions
• Business perspective: traditional versus modern operating models for service 
  transactions
• Building a business case for stakeholder buy-in (for example, business case 
  for centralization of service functions)

What is a chargeable service?

• What is a chargeable service?
• What are the relevant considerations to determine whether a service has been 
  rendered?
• What are low-value-adding services?
• Procurement
• What are the documentation requirements related to services?

Determining arm’s length remuneration

•  What are the charging methods?
• When is the indirect charge method allowed?
• What allocation keys are there and when should which allocation key be used? What 
  are the challenges and how can you deal with them?
• Which transfer pricing method should be used?
• Is it necessary to include a profit element?
• When can services be “passed through” i.e. charged without a markup? 
  Example US services cost method.
• How should the arm’s length charge for low-value-adding services be determined? 
  What are the complexities and challenges?
• How should accounting recognition be dealt with?

Cost sharing arrangement and cost contribution arrangement

• What are cost sharing arrangements/cost contribution arrangements? 
  What is the difference?
• When are CCAs/CSAs used for service transactions? Example franchise
• What types of cost contribution arrangements exist?
• How should the value of the contribution of the participants be determined?
• What is considered a contribution? When is a party considered to be 
  a participant?
• What is considered a benefit from the cost contribution arrangement?
• What is a balancing payment and how should it be dealt with?
• How should buy-in and buy-out payment be dealt with?
• How should entry, withdrawal or termination be dealt with?
• What are the documentation requirements with respect to cost contribution 
  arrangements?

Dealing with Intra-Group Services within a Multinational Enterprise (All except tax inspectors from tax administration)

• What are the factors to consider when deciding whether to centralize or 
  decentralize service activities within an MNE?
• How to deal with highly challenged intra-group management services 
  and head office expenses?
• How to set up a robust operating model for service activities of an MNE?
• How to avoid the disallowance of service charges?
• How to build the transfer pricing policy for services in your organization?

Skills practiced and developed during the course include:

• Identifying the traditional versus the modern operating models for services transactions
• Defining the policy framework and the importance of robust pricing of intragroup service transactions for MNEs and tax authorities
• Defining the business perspective to build a business case for stakeholder buy-in
• Defining the concept of chargeable and non-chargeable services
• Applying the general principles applied in determining an arm’s length remuneration for intragroup services
• Defining transfer pricing considerations and the framework for analyzing cost sharing and cost contribution arrangements
• Assessing how a multinational business model can impact the strategy for structuring intragroup management services

The course is open for all; however, it would be highly beneficial for:

• Tax lawyers from law/and or accounting firms
• Tax/TP managers of law/accounting firms
• Tax/TP managers/directors of MNEs
• Finance manager/controllers/treasury managers of MNEs
• Tax inspectors from tax administrations

This course may also be considered essential for individuals preparing for CIOT ADIT Module 3.03 – Transfer Pricing option, though it is not specifically designed for the ADIT. More information about this qualification can be found on the CIOT ADIT website.

No advance preparation is necessary. All required study material is provided within the online training.

• Luis Coronado, EY | Singapore
• Rajesh Bheemanee, EY | Singapore
• Shee Boon Law, DLA Piper | The Netherlands
• Sharon Tan, EY | Singapore
• Sandra Esteves, SABIC | The Netherlands
• Tanya Gartsman, Mazars | The Netherlands
• Gobi Varatha-Rajan, DLA Piper, United Kingdom

Access to the online course is granted for a period of 2 months, from the date of ordering or the indicated start date.

Mandatory course activities: : 6 hours 57 min

All mandatory course activities can be completed within the access period by dedicating minimum 1 hour of study per week. Please note that study materials included in the course or certificate programme will be accessible for the duration of the access period only. Non-mandatory supplementary material is also provided in this course.

We recommend you check with your respective accrediting organizations to determine the eligibility of CPE credits.

International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

Recommended NASBA CPE credits for this course is: 8

See our FAQ section for more information. Regarding administrative policies such as complaint, cancellation or refund, please refer to our Terms and Conditions or contact us at info@ibfd.org.

Field of study: Taxes

Delivery format: Online - QAS Self Study

Course Review : This course was last reviewed in January 2025

Please note that the content of this online course is subject to change based on updates in industry standards, regulatory requirements, and other developments. We strive to provide the most accurate and current information; however, we recommend verifying any critical details independently.

Group Participation

If you are an enterprise and would like to register a group of more than 5 participants from your company, please email us at info@ibfd.org for more details.