This article is the last of a series of three posts dealing with non-chargeable intra group services: Shareholder Activities, Duplicate Activities and Incidental Benefits. This post will specifically focus on the delineation of incidental benefits. To get the bigger picture, transfer pricing rules and the standard on which it relies, the arm’s length principle, considers…

Duplicate activities? Duplicate services are defined in the 2017 Transfer Pricing Guidelines (TPG) of the OECD as “activities undertaken by one group member that merely duplicate a service that another group member is performing for itself, or that is being performed for such other group member by a third party.” [1] Those activities are expressively…