The initial step in applying the simplified approach to low value-adding intra-group services is for the MNE group to calculate, on an annual basis, a pool of all costs incurred by all members of the group in performing each category of low value-adding intra-group services. The costs to be pooled are the direct and indirect costs of rendering the service as well as, where relevant, the appropriate part of operating expenses (e.g. supervisory, general and administrative). The costs should be pooled according to category of services, and should identify the accounting cost centres used in creating the pool. Pass-through costs in the cost pool should be identified for the purposes of applying paragraph 7.61. The cost pool should exclude costs that are attributable to an in-house activity that benefits solely the company performing the activity (including shareholder activities performed by the shareholding company).
Chapter VII paragraph 7.56
Category: Chapter VII: Special Considerations for Intra-Group Services, D. Low value-adding intra-group services, OECD Transfer Pricing Guidelines (2017) | Tag: Application of the simplified approach, Intra-group services, Low value-adding services (LVAS), Pass through costs, Pool of cost, Service fee, Services, Shareholder activity« Prev | Next »