Part One of our articles focusing on intra-group services in Cambodia highlighted the importance of Cambodian taxpayers being able to fundamentally prove that intragroup services were actually rendered by its related party and that these services justified a charge being made by its related party. Highlights of this note Risk created by Head Office approach […]

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 […]