An unfortunate series of divergent views - service transactions as a transfer pricing dispute engine

The treatment of service transactions and the allocation of income with respect to intangibles contributed by a controlled party to such transactions are being scrutinized by tax authorities in the light of the shift towards a services economy by both the developed and developing economies. The author takes a look at the temporary regulations issued by the United States in 2006 and then proceeds to discuss some of the positions taken by developing economies on services.