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Intra Group Services – Are Cambodian taxpayers waving a red flag to the GDT? Part Two

Intra Group Services – Are Cambodian taxpayers waving a red flag to the GDT? Part Two

October 21, 2021

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 to intra-group services
  • Recap on relevant domestic law
  • Importance of using correct methodology
  • Importance of financial benchmarking
  • What Cambodian taxpayers should do next

AUTHOR

Kieron is an ACCA-qualified, international tax professional with 10 years of experience, including four years in Cambodia. Recognized as the leading transfer pricing specialist actually located in Cambodia, Kieron established and led KPMG’s transfer pricing practice in Cambodia. He has completed thousands of transfer pricing projects, including over 250 in Cambodia, such as preparing transfer pricing documentation in Cambodia and Vietnam for a Japanese-based banking group and saving millions of dollars in tax assessments on a Cambodian transfer pricing audit for a petroleum company. Kieron also has extensive and wide-ranging experience in M&As, IPO readiness exercises, cross-border transaction structuring, and tax regime advocacy across a range of industry sectors, with a particular focus on the energy, banking, real estate, and manufacturing sectors.


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