Over the five years since the enactment of the most recent transfer pricing legislation, most companies have, more or less, accepted the need to ensure that their cross-border, intra-group product flows, royalties and management charges are set on an arm’s length basis and fully documented. However, the same cannot always be said with regard to intra-group financing and the provision of treasury services. This is despite the fact that the Inland Revenue has always maintained, quite correctly, that these transactions fall within the scope of the legislation.
