Supporting tax dedcutability of “intra-group” expenses and cost recharges

This service involves the preparation of contractual documentation and the required set of documents that support tax deductability of intra-group services (management services, IT services and other intercompany services within the group).

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.

In such engagements, allocation of “group” expenses is performed in the following steps:

  1. Preparation of agreements containing a clear pricing mechanism
  2. Communication with the bank and the parent company regarding the need to provide supporting documents
  3. Assistance with development of source documents that confirm the fact of providing services
  4. Creation of a separate mailbox for prompt collection of correspondence related to intragroup services (if relevant)
  5. Documentation of communications with the Company that provides intragroup services

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


Andriy Zelenskyy

Andriy Zelenskyy

Manager, Tax & Legal

Andriy’s experience comes from more than seven years of professional activities, of which over five years are in tax consulting. He specializes in tax support of audits, tax reviews, tax due diligence... More