The service that involves the preparation of contractual documentation and other documents required to support the rendering of intragroup services is provided in cooperation with our team of lawyers.
- Consulting projects on cross-border intra-group transactions are implemented in the following stages:
- Preparation of agreements containing a clear pricing mechanism.
- Communication with the bank and the parent company regarding the need to provide supporting documents.
- Assistance with development of source and additional documents that confirm the fact of providing services.
- Documentation of communications with the company that provides intra-group transactions.
The deliverables provided to clients include:
- Draft intercompany service agreement.
- List of intercompany services that are actually rendered within the group with a short description of their nature.
- Analysis of the identified services for their compliance with the OECD Transfer Pricing Guidelines for multinational enterprises.
- Assessment of the impact that the services rendered by the group's companies make on the company's activities, including its financial performance.
- Set of supporting documents (including electronic correspondence) for each service.
- A defense file with substantiation of business purpose of intra-group transactions that may be submitted to the tax authorities (if required).