Intra-group services and their tax implications

We will acquaint you with the tax implications that may arise when providing services within a group of companies. We will focus on transfer prices and cost sharing. Attention will also be drawn to instances in which the provision of services may lead to the formation of a permanent establishment and to instances in which payments for services may be subject to withholding tax.

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.