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Intra Group Services – Are Cambodian Taxpayers Waving a Red Flag to the GDT? Part One

September 20, 2021

For many developing countries, one of the most common types of related party transactions is intra group services. This could be domestic, but is predominantly cross border services provided by Regional or Ultimate Headquarter/Group Service Centers.

This Article discusses why so many Cambodian taxpayers are exposing themselves to a high level of transfer pricing audit risk in respect of their intra group services expense after Service Centers.

Highlights of this note

Introduction: Why this topic matters;
Why VDB Loi: How can we help?;
Background: The Law itself;
Conclusion – What to do next.

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Intra-Group-Services–Are-Cambodian-Taxpayers-Waving-a-Red-Flag-to-the-GDT-Part-1.pdf

AUTHOR

Kieron Gaffney
Director

Kieron is an ACCA-qualified, international tax professional with 10 years of experience, including four years in Cambodia. Recognized as the leading transfer pricing specialist actually located in Cambodia, Kieron established and led KPMG’s transfer pricing practice in Cambodia. He has completed thousands of transfer pricing projects, including over 250 in Cambodia, such as preparing transfer pricing documentation in Cambodia and Vietnam for a Japanese-based banking group and saving millions of dollars in tax assessments on a Cambodian transfer pricing audit for a petroleum company. Kieron also has extensive and wide-ranging experience in M&As, IPO readiness exercises, cross-border transaction structuring, and tax regime advocacy across a range of industry sectors, with a particular focus on the energy, banking, real estate, and manufacturing sectors.

KEYWORDS

Intra Group Services, the General Department of Taxation (“GDT”)

RELATED EXPERIENCES

Taxation