The Resource Management fees and other intra-group service charges - part I

Management fees and other intra-group service charges - part I

Label
Management fees and other intra-group service charges - part I
Title
Management fees and other intra-group service charges - part I
Creator
Subject
Language
eng
Summary
In essence, as amply demonstrated by a number of transfer pricing litigation cases involving management fees in Canadian and American courts in recent years, intra-group services are perhaps among the most controversial issues in the realm of transfer pricing. In this context, it is worthwhile revisiting the fundamentals concerning intra-group services with respect to the applicable legislation and case law in Canada and the United States to more clearly address the most important issues that multinational taxpayers should take into account when evaluating their intra-group service transactions. Towards this end, this series of four articles addresses the core areas. This first part covers a survey of fundamentals including definitional perspectives and an overview of the legislative framework to evaluate intra-group services in the North American context
Citation source
In: Tax planning international transfer pricing. - London. - Vol. 7 (2006),
http://library.link/vocab/creatorName
Przysuski, M
Geographic coverage
  • North America
  • North America
Language note
English
http://library.link/vocab/subjectName
  • management fee
  • intra-group services
  • transfer pricing
  • OECD Transfer Pricing Guidelines
  • US Transfer Pricing Regulations
  • withholding tax
  • tax treaty
  • exemption
Label
Management fees and other intra-group service charges - part I
Instantiates
Publication
Label
Management fees and other intra-group service charges - part I
Publication

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