For the purposes of the transactions under the scope of the Circular issued, it must be determined for each intra-group transaction
whether it complies with the arm's length principles.
"This intra-group transaction
is the last step of a process developed since the beginning of 2009 to reinforce links between Credit Agricole SA and Emporiki Group's subsidiaries," Emporiki said in a statement.
For Sistema, the deal essentially is an intra-group transaction
that transfers the debt burden it would otherwise have to assume to Bashneft.
. For the Commission, the tax base should not include the profits or the losses made during a intra-group transaction
in the framework of the group consolidation.
The second set of documentation (country-specific documentation) will be addressed by the company to each country involved in the intra-group transaction
. These documents should contain information on the flow and the billing of transactions as well as the contractual clauses and the particular methods used to determine the transfer prices.
3 Search and Search related advertising revenues exclude intra-Group transactions
The composition of HSBC France's capital base has been further aligned with the group's standards through intra-group transactions
(Additional Tier 1 and Tier 2 instruments fully subscribed by HSBC Bank plc).
The Guidelines should also recommend, but not require, reasonable allocation keys for defined types of intra-group transactions
. Helpful allocation keys would be: (i) allocating human resources cost by relative headcount; (ii) allocating marketing expenses by relative revenue; and (iii) allocating information technology costs, including software licenses, by computer user count.
Other key recommendations include continually monitoring tax developments and updates, assessing the financial impact of VAT on their business models, internally reviewing financial systems to assess overall tax readiness, upgrading points of sale systems to capture VAT-related information, determining intra-group transactions
and dependencies and re-visiting contract clauses dealing with price and taxes.
"As a GCC VAT system, UAE businesses, which have operations in other GCC member states, must examine the impact of the special rules on intra-GCC supplies and acquisitions and intra-group transactions
to ascertain whether the current organisation model will remain effective after the new VAT system is implemented," said Sexton.
This tax planning tool provides you with quick answers on how to best structure your intra-group transactions
regarding dividend repatriation, fees, royalties and financing.
Karas also announced that the EPP group would propose to tax over-the-counter transactions more heavily than stock market transactions, to set fixed rather than minimum tax rates and to exclude intra-group transactions
from the FTT.