Intra-group services: topical aspects of international taxation and tax risk analysis

This research is devoted to the scientific analysis of the current methodological aspects of the legal qualification of intra-group services for taxation purposes within the framework of international and Russian legal regulation, as well as model guidance documents of the OECD and the UN. Structurally, the research consists of two chapters and five paragraphs. The first chapter provides a comparative legal analysis of the international approach to the institution of intra-group services and current models of regulation of intra-group services provisions in foreign jurisdictions, presents the author's approach to the systematisation of tax tests for the legal qualification of intra-group services on the basis of modelled cases, and also considers topical issues regarding the application of the direct and indirect method of charging for intra-group services. The second chapter analyses the peculiarities of the intra-group services regulation in the Russian Federation and the key Russian court practice on tax disputes in the field of intra-group services in the context of the given methodological considerations. In the conclusion the author, taking into account the formulated scientific conclusions, proposes measures to improve tax policy in the aspect of regulation of intra-group services.