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Companies A , B and C are related companies of the group of companies ABC. Company A is the mother company of B and C

Companies A, B and C are related companies of the group of companies ABC. Company A is the mother company of B and C and is holding a participation in both B and C at the rate of 55%. The mother company A is a belgian legal entity, company B is a greek legal person and company C is an italian legal person. The revenues of the company B at the year 2024 are expected to exceed the amount of 6 M . The management of Company B is discussing with the management of Company C in Italy regarding the conclusion of a contract for the provision of supporting services in the sector of sales and procurement. Service provider will be the Greek legal person and service recipient will be the italian legal person. The amount of the transaction is expected to exceed for the tax year 2024 the amount of 0,8 M . You are the Tax Director of the Company B and before preparing the contract, you are invited by the members of the Greek Company to express your thoughts regarding the transactions. In addition you are asked what kind of additional obligations will arise due to this transaction regarding the transfer pricing and the relevant tax issues. Please give in 2.500-3.000 words your holistic approach regarding tax aspects of this transaction and the related tax obligations, but only regarding transfer pricing, in order to ensure the tax compliance of you employer. Your answer should include your involvement during the conclusion of the agreement and after the closure of the tax year (e.g. tax obligations etc), taking into consideration that the financial figures given above finally were realized. You are kindly requested to approach the given case only from the perspective of transfer pricing.

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