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A company owning 100% of four other companies asks whether it can charge a monthly fee for administrative, accounting and IT support services. The DGT responds that, as group entities, transactions must be valued at market value and services must generate an advantage or benefit to the recipient.
Question posed: Whether the consulting entity may provide administrative, accounting, and IT support to the participated companies, and invoice a monthly fee at market price for such services rendered.
The consulting and participated entities are related parties; therefore, their transactions must be valued at market value pursuant to Article 18 of the LIS. The choice of valuation method for the invoicing of services is at the discretion of the entities, without prejudice to the Administration's power of verification. Furthermore, intra-group services must provide an advantage or benefit to the recipient, and their existence or value is a matter of fact.
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