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Intra-group fees can be deductible for corporation tax purposes if paid for product sales by another group company or other support of the company's operations.
The Supreme Administrative Court reached this important decision in a case run by CMS Cameron McKenna’s tax team. It has yet to provide written details of its reasoning but is expected to do so shortly.
The court also ruled that the tax authority should actively cooperate with the taxpayer to establish an acceptable level for the fees payable.
