Consulting on cross-border intra-group transactions

This is a service that involves the preparation of contractual documentation and the package of documents required to confirm the expenses incurred to acquire intragroup services (management services, intercompany services), as well as the deductibility of VAT input.

The service that involves the preparation of contractual documentation and other documents required to support the rendering of intragroup services is provided in cooperation with our team of lawyers.

  1. Consulting projects on cross-border intra-group transactions are implemented in the following stages:
  2. Preparation of agreements containing a clear pricing mechanism.
  3. Communication with the bank and the parent company regarding the need to provide supporting documents.
  4. Assistance with development of source and additional documents that confirm the fact of providing services.
  5. Documentation of communications with the company that provides intra-group transactions.

The deliverables provided to clients include:

  • Draft intercompany service agreement.
  • List of intercompany services that are actually rendered within the group with a short description of their nature.
  • Analysis of the identified services for their compliance with the OECD Transfer Pricing Guidelines for multinational enterprises.
  • Assessment of the impact that the services rendered by the group's companies make on the company's activities, including its financial performance.
  • Set of supporting documents (including electronic correspondence) for each service.
  • A defense file with substantiation of business purpose of intra-group transactions that may be submitted to the tax authorities (if required).


Vasyl Drobot

Vasyl Drobot

Director, Tax&Legal

Vasyl has more than 10 years’ experience in providing tax consulting services. He specializes in tax due diligence, tax audits and reviews, support to companies during audits by tax authorities, tax c... More

Return to: Corporate Taxation