TRANSFER PRICING & INTRA-GROUP SERVICES
Managing VAT and indirect taxes with precision and confidence
Evolving Regulatory Environment
Cross-border groups are operating in a landscape of increasing transparency and heightened regulatory expectations. Tax authorities across Europe are placing greater emphasis on the accurate identification, allocation and pricing of intra-group activities, with a particular focus on service arrangements and financial transactions.
European and Cypriot Context
As EU jurisdictions align more closely with OECD guidance, consistency and technical support for intercompany charges have become essential. Cyprus has adopted the OECD Transfer Pricing framework in full, creating clear compliance requirements for groups with cross-border operations. High-quality documentation is now a key element in managing uncertainty, demonstrating substance and supporting the integrity of the tax position.
Intra-Group Services (SITs)
Intra-group services remain one of the most scrutinised areas in transfer pricing. Effective SITs analysis requires clarity over the nature of the services provided, the benefits received by each entity and the rationale supporting cost allocation. Robust documentation helps reduce exposure to challenges around duplication, shareholder activities and inappropriate allocation keys.
Transfer Pricing
Transfer pricing frameworks support the pricing of intercompany transactions, including services, financing, distribution and the use of intangibles. OECD-aligned documentation provides a clear, defensible basis for these arrangements and plays a critical role in managing audit risk across multiple jurisdictions.
SITs – Intra-Group Services Support
We assist in developing SITs documentation that provides:
- Clear descriptions of the services performed and the entities involved
- Benefit analyses aligned with OECD expectations
- Supportable cost allocation methodologies
- Assessment of duplication and shareholder-activity considerations
Our approach ensures your service arrangements are consistently documented and aligned with regulatory standards.
Transfer Pricing Documentation & Advisory
We support groups in meeting TP requirements through:
- OECD-compliant documentation for intercompany transactions
- Benchmarking and economic analyses
- Reviews of financial transactions, including loans and guarantees
- Identification of technical and operational risks
- Practical recommendations to enhance compliance and defensibility
Our experience with international structures enables us to deliver documentation that is technically sound, transparent and ready for regulatory review.