One example involves debt-factoring activities, where an MNE group decides to centralise the activities for economic reasons. For example, it may be prudent to centralise the debt-factoring activities to better manage liquidity, currency and debt risks and to provide administrative efficiencies. A debt-factoring centre that takes on this responsibility is performing intra-group services for which an arm’s length charge should be made. A CUP method could be appropriate in such a case.
TPG2017 Chapter VII paragraph 7.39
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Debt factoring, Example - services, Intra-group services, Service fee, Services
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