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)?

FAME · September 10, 2024, 5:02am

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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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)?

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