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ARTICLE · 19 MARCH 2026

Intra-group Services: OECD Guidelines And Remuneration Criteria

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Understand how the OECD Guidelines guide the substantiation, pricing, and determination of remuneration for services provided between companies within the same corporate group

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Understand how the OECD Guidelines guide the substantiation, pricing, and determination of remuneration for services provided between companies within the same corporate group

The blog "International Taxation," is a space dedicated to the qualified analysis of relevant topics in Tax Law applied to cross-border operations. Coordinated by Tax partner Victor Polizelli and international tax specialist Javier Bonilla, the blog seeks to deepen technical and practical discussions that impact the reality of multinational companies.

In this post, we address intra-group services from the perspective of the OECD Guidelines, exploring fundamental concepts, evidentiary criteria, remuneration methods, and reflections on the application of margins. Read the full text below, followed by its Spanish version.

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