Multinational groups will be required to demonstrate the commercial benefits subsidiaries expect to receive from such services and justify the amounts they are willing to pay over multiple years.
Multinational companies could face tougher documentation requirements under proposed changes to the Organisation for Economic Co-operation and Development (OECD) transfer pricing guidelines, as tax experts warn the reforms may increase compliance obligations while offering greater clarity on cross-border transactions.
The draft guidelines, released for public consultation earlier this year, focus on intra-group services—transactions between parent companies and their foreign subsidiaries, such as management support, software licensing, technical assistance, financial advisory services and other shared corporate functions.
