According to the OECD Guidelines1, there are two main issues when analysing intra-group services:
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•ÌýÌýÌýÌý whether an intra-group service that should be charged for has been provided, which is outlined below, and
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•ÌýÌýÌýÌý what is the arm's length charge for that service (see B4.147)
In determining whether a service has been provided to a related party, it is necessary to look at all surrounding facts and circumstances. It is not possible to establish a set of strict criteria to determine if an activity amounts to a service provided. However, there are generally accepted considerations to determine whether services have been provided.
A service is considered to have been provided when activities are performed for another party who receives,
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