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.
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