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My company is considering setting up shared regional services locations for N America, Europe and Asia. Does anyone have recent experience with this they could share? Helpful issues would be: - attractive/unattractive countries - local advisers that are particularly helpful - sample agreements - mark ups used to satisfy transfer pricing concerns Has anyone done this with non-wholly owned groups, where you are actually at arm’s length?

International Tax Planning
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Gary Gottlieb
Hi,

I have some significant experience with this. It's imporatnt before hand to get all the planning right or woe betide you at a later stage. 

Mark-ups for services are generally based on cost plus, and as the services are usually of an admin nature, they tend to be in the quite low range.

Again, chosing the corrct country is not only a tax issue, but an operational issue, you want a location where you can source talent that will be able to effectively carry out the services required, otherwise it's going to cost you a lot more in the long run then tax.

If you need any assistance with this still, please let me know.

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