Do the services provided by one or more Group entities to other entities of the Group need to be at Arm’s Length (Intra-group services)?

Transfer Pricing
1

Do the services provided by one or more Group entities to other entities of the Group need to be at Arm’s Length (Intra-group services)?

2

Yes, the intra-group services need to be at Arm’s length wherein the service provider should apply a markup to all costs that are not pass-through in nature. The taxable person must maintain supporting documentation which includes inter-alia the following:

  • explanation of the intra-group services provided
  • summary of the benefits received
  • the approach adopted to determine and calculate the charges
  • justification for the choice of allocation key(s) used

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