The regulations of Treasury and IRS final intercompany service were issued on 31 July 2009. Some permitted transfer pricing methods for services are similar to the OECD methods but the services cost method and shared services arrangements are also contained in the regulations. The fee for certain types of service known as covered services may be arrived at by the apportionment of costs that are recharged to other group companies without a mark-up. Covered services are specified routine services such as payroll, administration, accounting and legal services. The taxpayer must apply the business judgment rule to determine that the services do not make a significant contribution to the competitive advantage, core capabilities or fundamental risk of success or failure of the group. Shared services arrangements are another method for allocating centralized services among members of the group in a reasonable manner using a suitable allocation key.
South Korea – Seeks Tax from Gold Trading
Related Posts

US restricts aircraft parts to China in trade standoff
The Trump administration has begun limiting aircraft component exports to China as part of a broader strategy to gain
Read More
US: IRS seeks volunteers for free tax preparation programmes
The US Internal Revenue Service (IRS) announced, on 1 October 2026, that it is recruiting volunteers and community
Read More
US: Trump Administration weighs diesel export ban amid rising fuel costs
The Trump Administration is actively considering a diesel export ban as fuel prices continue climbing across the US.
Read More
US: Court challenges Trump’s ‘forced labour’ tariffs
The US Court of International Trade heard arguments on 30 September 2026 over the legal validity of President Trump's
Read More
Bangladesh gets US tariff exemption on medicines, APIs
The US has exempted specified medicines and Active Pharmaceutical Ingredients (APIs) from import tariffs for 20
Read More
US considers fuel tax relief as diesel prices reach record highs
The Trump administration is evaluating regulatory changes to lower fuel prices as diesel climbs to historic levels. The
Read More