Cost allocations for intra-group services based on the 2017 OECD Guidelines J. Christian Plesner Rossing and Anthony F. Falcone Electrónico
By: Plesner Rossing, Christian
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Contributor(s): Falcone, Anthony F
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Material type: 




Item type | Current location | Home library | Call number | Status | Date due | Barcode |
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Recursos electrónicos | IEF | IEF | ITPJ/2020/5-9 (Browse shelf) | Available | ITPJ/2020/5-9 |
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Disponible únicamente en formato electrónico.
Resumen.
Intra-group services in multinational enterprises (MNEs) continue to be scrutinized by tax authorities during transfer pricing audits. While many MNEs have significant experience with intra-group services, some continue to struggle with managing their intra-group service cost allocations in a compliant and transparent manner. In this article, an applied theoretical model is proposed that MNEs can use when (re)designing their cost accounting practices for intra-group services. The model is based on the 2017 OECD Guidelines, including the low value-adding service concept introduced in the 2017 revision of chapter VII of the OECD Guidelines.
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