Intra-group services and their tax implications

Who are the intended participants?

• Tax, accounting and controlling specialists involved in the process of setting transactions between group companies and their reporting in the accounting and tax records.
• Executives who make decisions about the design or the change of business models from a tax perspective.

Programme

• The provision of services from a transfer pricing point of view.
• The cost sharing concept versus the provision of services (pros and cons).
• Pricing issues – allocation of expenses, application of mark-ups and other aspects of pricing.
• Benefit test – how to proceed?
• The specifics of management fees.
• Year-end transfer pricing adjustments.
• BEPS - base erosion and profit shifting.
• Secondment, the issue of an economic employer, the risk of forming a permanent establishment.
• Application of withholding tax.
• Practical examples.

Benefits

After completing the training, you will be able to:

• Identify what risks may arise to the company from its current intra-group service arrangement.
• Evaluate proposed or existing models of intra-group services and identify potential deficiencies.
• Assess whether or not it is appropriate to apply a profit mark-up.