Transfer Pricing

Intercompany Service Fee Arrangements

Intercompany Service Fee Arrangements

NERA has developed a robust documentation framework for intercompany services that has been used successfully worldwide. This framework consists of a structured approach to valuing arm’s length service fees.

NERA's approach to documenting intercompany services begins with a thorough understanding of the functions and costs associated with the clients' relevant business units.

  • After performing a robust gathering of facts, we group costs into distinct service categories.
  • We independently review each service category to determine which costs are related to stewardship activities, routine activities, and non-routine services.
  • Service costs are then allocated to determine what portion of costs in each category is chargeable to affiliates. 
  • Arm's length fees for non-routine services are calculated rigorously through an economic benchmarking process that is expansive and comprehensive.
  • Finally, we integrate various elements of the structured approach to calculate total service fee charges for related parties.

NERA's structured approach to documenting intercompany service charges leads to increased defensibility under audit because all service fee charges can be traced back to their original source data.

  • We use routine accounting data that is created and maintained during the ordinary course of business, enabling our clients to easily update and maintain this framework in-house.
  • We rely upon information that is in the public domain and only employ analytical tests that are verifiable within the delivered documentation to provide our clients with work that has lasting value.
Name Title Location Phone Email
Yves Hervé Managing Director Frankfurt +49 69 710 447 508
Dr. Harlow Higinbotham Managing Director Chicago +1 312 573 2803
+86 21 6103 5544
+86 10 6533 4395
Dr. Emmanuel Llinares Managing Director
Head of Global Transfer Pricing
+33 1 70 75 01 93
+41 22 819 94 94
+44 20 7659 8650
Sébastien Gonnet Director Paris + 33 1 45 02 30 00
Nihan Mert-Beydilli Associate Director Los Angeles +1 213 346 3035
Yuko Saito Associate Director New York City
+1 212 345 1963
+81 3 3500 3378
Dr. Vladimir Starkov Associate Director Chicago +1 312 573 2806
Tom Braukmann Principal Frankfurt +49 69 710 447 511
Guillaume Madelpuech Principal Paris +33 1 70 75 01 58
Title Type Author
Comments on OECD Discussion Draft on the Revised Guidance on Profit Splits Regulatory Filing Emmanuel Llinares, Harlow Higinbotham, Nihan Mert-Beydilli, and Vladimir Starkov
Recent Developments on the Profit Split Method Book Sébastien Gonnet
Apple and the CCCTB: Can the European Commission Have Both? Published Article By Dr. Emmanuel Llinares and Guillaume Madelpuech
Economic Analysis for Developing Countries—Comments on the IMF, OECD, UN, and World B... Regulatory Filing By Dr. Vladimir Starkov, Sébastien Gonnet, and Guillaume Madelpuech
Field Tax Audits in Germany Published Article By Dr. Alexander Voegele and Philip de Homont
The take on comparables: A French perspective Published Article By Guillaume Madelpuech
Comments on the OECD Public Discussion Draft on the Attribution of Profits to Permane... Regulatory Filing By. Pim Fris and Guillaume Madelpuech
Separating intangible value by surveys Published Article By Philip de Homont and Alexander Voegele
Risks Redefined in Transfer Pricing Post-BEPS Book By Sébastien Gonnet
Discussion of the Amendments to Chapter IX of the OECD Transfer Pricing Guidelines on... Memo By Pim Fris and Guillaume Madelpuech