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

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.