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: Congressional Research Service (CRS) reviews TCJA changes to cost recovery, R&D tax credit
The US Congressional Research Services (CRS) has published a new "In Focus" report, “How the "Tax Cuts and Jobs Act" (TCJA, P.L. 115-97) Changed Cost Recovery and the Tax Credit for Research” on 13 November 2024. Tax benefits for investments
Read MoreUS: Treasury Department finalises rules for expanding clean energy tax credits
The US Department of the Treasury and the IRS, in a press release on 19 November 2024, issued final regulations that will expand the reach of the Biden-Harris Administration’s Inflation Reduction Act by helping entities that co-own clean energy
Read MoreUS: Treasury Department’s CDFI Fund to grant USD 10b in NMTC authority for 2024-25
The US Department of the Treasury's Community Development Financial Institutions Fund (CDFI Fund), on 19 November 2024, released the Notice of Allocation Availability (NOAA) for the next round of the New Markets Tax Credit Program (NMTC
Read MoreHungary ratifies new CbC reporting pact with US
Hungary’s President has signed Law No. XLIII of 2024, officially ratifying the new Country-by-Country (CbC) reports exchange agreement with the US. The ratification was published in the Official Gazette No. 113 (Magyar Közlöny) on 13 November
Read MoreUS lowers tax interest rates for Q1 2025
The US Internal Revenue Service (IRS) announced in release IR-2024-290 on 18 November 2024 that interest rates will decrease for the calendar quarter beginning 1 January 2025. For individuals, the rate for overpayments and underpayments will be
Read MoreUS: FinCEN updates FAQs on beneficial ownership access
The US Treasury Department's Financial Crimes Enforcement Network (FinCEN) has revised its FAQs on beneficial ownership information reporting requirements on 15 November 2024. These updates include changes to two specific FAQs regarding access to
Read More