Overview
Multinational enterprises (“MNEs”) often employ intra-group services as a means of enhancing efficiency and realising cost savings by centralising services delivery to group entities. These are often offered by multiple group entities, a head office, or a Shared Service Centre designated by the group.
During the majority of transfer pricing audits, the ZRA carefully evaluates intra-group service transactions critically. There are various factors that either support or do not support the arm’s-length nature of intra-group services as outlined in this article.
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