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

Resource Information

The work Management fees and other intra-group service charges - part I represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

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

Creator

• Przysuski, M

Subject

• US Transfer Pricing Regulations
• exemption
• intra-group services
• OECD Transfer Pricing Guidelines
• tax treaty
• transfer pricing
• withholding tax
• management fee

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),

Geographic coverage

• North America
• North America

Language note

English