Compensation for intra-group transactions and services between related parties must often be acknowledged by tax authorities in order to guarantee an appropriate taxation and avoid tax adjustments. Therefore, a confirmation from tax authorities regarding the tax treatment of intra-group transactions on a case-by-case basis via ruling (i.e. request aiming at confirming the tax treatment of a particular set of facts) appears often necessary.
IFN offers tax advice in relation to intra-group transactions and takes all necessary steps before tax authorities.
Areas of expertise