Intra-group transactions

Intra-group transactions

Intra-group transactions. Financial and service costs. Transfer pricing analysis and risk assessment. Advance pricing agreements. Exit tax

Intra-group services. Financing costs. Deductibility limits. Exit tax

In recent years OECD focuses its efforts on introducing a number of measures to prevent tax avoidance and evasion (BEPS initiative). On that account, the tax authorities pay more attention to intra-group transactions.

Currently, the majority of enterprises acting as a part of multi-national group provide intra-group services such as e.g. administrative services, technical services or financial services. Such services concern mainly functions related to management, coordination and control over the whole group.

Therefore, the International Corporate Tax Team offers the following services to its Clients:

  • reviews of intragroup transactions with regard to the statutory limitations of tax deductible costs (services, financial costs);
  • analysis of intragroup transactions in order to assess the risk of applying anti-avoidance provisions (e.g. GAAR, exit tax) and to mitigate these risks (verification or assistance in preparation of defence files);
  • application for tax rulings covering purchase transactions with related entities (services, royalties, financial costs);
  • support of taxpayers in proceedings regarding the advance pricing agreements;
  • analysis of intragroup transactions and cash flows in terms of compliance with reporting obligations (e.g. withholding tax);
  • preparing the statutory transfer pricing documentation.

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