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
Vietnam to expand US imports of machinery, high-tech products, energy resources
Vietnam has signalled plans to increase imports from the US, focusing on machinery, high-technology products, and energy resources, as the two countries conduct the sixth round of negotiations on the Vietnam–US Fair and Balanced Reciprocal Trade
Read More
US, Argentina expand trade deal, cuts tariffs
The US and Argentina have signed the United States–Argentina Agreement on Reciprocal Trade and Investment (ARTI) on 5 February 2026, which formalises a broad trade and investment agreement aimed at deepening economic and strategic ties between the
Read More
US: IRS releases US–Spain competent authority agreement on arbitration
The US Internal Revenue Service (IRS) has released Internal Revenue Bulletin No. 2026-6 on 2 February 2026. The bulletin includes Announcement 2026-3, which sets out the Competent Authority Arrangement agreed between the US and Spain to implement
Read More
US: Treasury, IRS release draft rules for clean fuel production credit under OBBB
The Department of the Treasury and the Internal Revenue Service (IRS) announced on 3 February 2026 the proposed regulations for domestic producers of clean transportation fuel to determine their eligibility for and calculate the clean fuel
Read More
Bangladesh to sign US tariff agreement ahead of elections
Bangladesh’s interim government will sign a tariff agreement with the US on 9 February 2026, just three days before the national parliamentary election. The delegation, led by commerce adviser Sk Bashir Uddin and commerce secretary Mahbubur
Read More
US imposes tariffs on countries supplying oil to Cuba
US President Donald Trump signed a new executive order titled “Addressing Threats to the United States by the Government of Cuba” on 29 January 2026. The order establishes a formal mechanism that would allow the US to impose additional ad
Read More