Intercompany Service Fee and Licence Charges under Extraordinary Circumstances

Journal
International
International Transfer Pricing Journal 2025 (Volume 32), No. 3
This article seeks to examine the appropriate tax treatment of unremunerated intra-group services and IP licences under extraordinary conditions, with reference to the OECD Guidelines (2022) and German tax law, particularly in light of the arm’s length principle. Several illustrative scenarios are analysed to support this assessment.