TPG2022 Chapter VII paragraph 7.47

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The following activities would not qualify for the simplified approach outlined in this section:

  • services constituting the core business of the MNE group;
  • research and development services (including software development unless falling within the scope of information technology services in 7.49);
  • manufacturing and production services;
  • purchasing activities relating to raw materials or other materials that are used in the manufacturing or production process;
  • sales, marketing and distribution activities;
  • financial transactions;
  • extraction, exploration, or processing of natural resources;
  • insurance and reinsurance;
  • services of corporate senior management (other than management supervision of services that qualify as low value-adding intra-group services under the definition of paragraph 7.45).

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