Intra-group intangible services

Taxpayers who enter into intangible transactions with related parties take on risk that some of the costs of those transactions will be deemed non-deductible. Where transactions are large and frequent, these items can be significant. Therefore we:

• Analyse taxes in terms of their tax deductibility
• Help taxpayers calculate tax deductibility quotas/limits
• Verify whether the documentation in place contains a sufficient justification of the expense and proof of the service provided
• Draft procedures for determining the deductibility of intra-group spending on intangible services