Registration Time:13:15
Sessions Time: 13:30 - 16:45  including a 15-minute break
Speaker: Ms Trudy Muscat
Venue:   Online Webinar

Participation Fees 
MIA Members: €40.00
Non-MIA Members: €75.00
Retired Members: €20.00
Students: €30.00

*Group bookings for 3 or more participants available.

BACKGROUND INFORMATION

This 3‑hour session will introduce participants to the transfer pricing treatment of intra‑group services with a focus on the OECD benefit test. It will explain how to distinguish genuine services from shareholder activities, duplicative services and incidental group synergies, and will touch on the concept of low‑value‑adding intra‑group services and simplified approaches. Recent international controversy trends and selected court decisions will be used to illustrate how tax authorities challenge management and head‑office fees, allocation keys and documentation. By the end of the session, participants will be able to identify and distinguish different types of intra‑group services, apply the OECD benefit test in practice, and critically assess facts and circumstances to understand how transfer pricing principles are applied to common day‑to‑day situations.

Specific topics to be covered during the sessioN

• Overview of intra group services for TP purposes
• The OECD benefit test: what it is and how to apply it in practice
• Distinguishing genuine services from shareholder activities, duplication and incidental synergies
• Low value adding intra group services (LVAS) and simplified approaches
• Typical intra group service models (cost plus, fixed fee, pass through) and how they are priced
• TP risks, practical issues and documentation
• Recent international cases and examples reflecting typical TP issues on intra group services

Why is the session of relevance to our members?

This session equips MIA members with practical tools to identify, price and document intra group services in line with the OECD TP Guidelines, reducing the risk of transfer pricing adjustments and double taxation. By working through international standards and real cases, participants will better anticipate tax authority challenges and strengthen the defensibility of their clients’ or organisations’ service charge arrangements.

Target Audience

Tax professionals, transfer pricing practitioners, and finance/legal personnel new to OECD TP principles, especially Chapter VII.

Speaker' Profile

A senior manager within Deloitte’s international tax team, Trudy is an experienced international tax lawyer with a demonstrated history of efficiently leading a team to support MNEs with cross-border and local tax. Fifteen years work experience in corporate local and international tax law, personal holding solutions, family business succession planning and legal drafting, with a specialisation in EU direct tax. Trudy has focused on the entertainment and tech industry in recent years and in particular on the local and cross-border impact of EU tax developments and transfer pricing.

EVeNT CPE COMPETENCies

3  Core

WEBINARS TERMS AND CONDITIONS

Terms and conditions  apply

DISCLAIMER

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Please note that all webinars are recorded by the MIA. Such recordings will be retained by the MIA for internal use.