Intragroup compliance, KYC, AML and blockchain analytics services
At year-end, the Ivorian subsidiary of a French group receives an annual invoice for EUR110,250 labelled “compliance and blockchain analytics services”. The Paris service centre administered screening software, reviewed KYC alerts and produced on-chain analyses. The invoice cannot be supported by the software cost or a headcount key alone. The file must show which services were performed, who benefited from them and why some expenditure is neither a shareholder activity nor a core function carried out for another entity.
The finance director has four separate decisions to document: identify the service, demonstrate the benefit expected or obtained by the subsidiary, assemble the correct cost pool and select remuneration consistent with the functions and risks. Each entity’s KYC and AML duties remain governed by the rules that apply to it. A group policy or common tool does not automatically transfer regulatory responsibility.
Start with the work actually performed
The file opens one line for each service family. Screening-tool administration, scenario maintenance, second-level alert review, address analysis, staff training and group reporting address different needs. They may involve different people, assets and risks.
Each line is linked to evidence: tickets, access logs, alert files, minutes, deliverables, time records and the intragroup agreement. A software subscription purchased by the parent does not by itself establish that a subsidiary received a service. Conversely, the absence of a formal report does not necessarily mean that no service was performed where the process leaves a verifiable trail.
EU Regulation 2023/1113 illustrates the level of precision required for certain crypto-asset transfers. Covered service providers must handle originator and beneficiary information and apply risk-based procedures when that information is missing. The Regulation does not apply indiscriminately to every group company. It nevertheless helps distinguish an operational control, a required data point and a documented decision from mere access to software.
Apply the benefits test entity by entity
Chapter VII of the OECD Transfer Pricing Guidelines asks whether an independent enterprise in comparable circumstances would have paid for the activity or performed it for itself. The question is therefore more specific than whether the group considers compliance useful. It requires the file to identify what the subsidiary receives and which economic decision the service supports.
For the Ivorian subsidiary, an address analysis used to approve a customer, a second-level review or a scenario update may provide a benefit. The file then describes how the deliverable was used, the local process it affected and the risk it addressed. A presentation to the parent’s board on consolidated exposure, with no action or deliverable for the subsidiary, may be a shareholder activity. Its cost should not automatically be spread across operating entities.
The review also covers duplication. If the subsidiary already pays a local provider for the same screening and the Paris centre repeats it without a documented reason, the second activity is not automatically chargeable. A second review may, however, satisfy a segregation-of-duties control or address higher risk. The file must explain that reason and the value of the additional intervention.
Separate support services from core functions
The OECD simplified approach for low-value-adding intragroup services is designed for supportive activities that are outside the group’s core business, do not use unique and valuable intangibles and do not create significant risk. It requires documentation of the benefit, cost pool, allocation keys and mark-up.
The label “compliance” does not automatically place a service in that category. For an industrial group, administration of a standard KYC tool may be supportive. For a crypto-asset service provider whose value proposition depends on risk detection and on-chain analysis, scenario design, models or specialist investigations may be part of the core business, use distinctive know-how or control significant risk. A full functional analysis and, depending on the facts, a different pricing method may then be required.
The OECD opened a consultation in 2026 on revisions to Chapter VII. The proposals do not replace the 2022 Guidelines unless and until they are finalised and adopted. The file therefore applies the current text and tracks the project separately as a possible future development.
Build a verifiable cost pool
Illustrative case. The Paris centre incurs EUR600,000:
• EUR60,000 relates to shareholder reporting and is excluded from the chargeable pool;
• EUR120,000 concerns investigations performed solely for another subsidiary and is directly allocated to it;
• EUR420,000 funds the common tool, standard scenario maintenance, training and shared alert review.
The shared pool is therefore EUR420,000, not EUR600,000. Accounts, cost centres and supplier invoices must allow a reviewer to reproduce the bridge. Directly attributable costs remain separate. Shareholder expenditure and amounts without an identified beneficiary are not diluted through a collective key.
The Ivorian subsidiary generated 1,500 weighted alerts out of 6,000 for the services in the shared pool, or 25%. If that volume reasonably reflects the benefit received, its share is EUR105,000. Assuming every condition of the simplified approach is met, a 5% mark-up would produce EUR110,250. The calculation explains the opening invoice: EUR420,000 × 25% × 1.05.
The result is not an automatic validation. The 5% mark-up under the simplified approach applies only to services genuinely within its scope. Specialist investigations, model ownership or control of a major risk may require separate analysis. Local documentation duties, tax rules and any withholding consequences also need to be assessed separately in each country.
Select a key that follows the benefit
One key for the entire compliance department often produces a misleading allocation. Headcount may fit general training but not a monitoring platform used by a limited set of accounts. Gross transaction counts may ignore complexity, while alert counts can change when thresholds are recalibrated.
The file therefore connects each cost family to an explainable driver: active users for licences, documented cases or time for reviews, weighted alerts for analytics and direct allocation for a dedicated investigation. It tests outliers and explains changes in the key. A matrix links the service, beneficiary, evidence, cost, key, mark-up and invoice.
Blockchain analytics data does not replace this analysis. The FATF highlights the usefulness of analytical tools alongside a risk-based approach, technical capabilities and cooperation. A risk score remains a control input. The group must record the rule applied, human review, decision and retained evidence.
The year-end deliverable
The BECTRA file contains a service map, an entity-level benefits test, a reconciliation of the cost pool, allocation keys with source data and a note supporting the remuneration method. Agreements identify the entities, nature of the services and charging terms and are reconciled to the work actually performed.
The final column records open items: shareholder activity, possible duplication, a core service, local law to verify, missing data or an allocation key that is too coarse. Tax and compliance owners can then review the same flow without confusing transfer pricing with the underlying regulatory obligation.
Conclusion
An intragroup invoice for KYC, AML or blockchain analytics is supported by the complete chain from work to beneficiary, cost and remuneration. The service name determines neither the benefit received nor access to the simplified approach. A year-end matrix makes exclusions, keys, assumptions and local-law questions visible to the reviewer.
Further reading
Sources
Official sources reviewed on 11 November 2026. The numerical case, allocation keys and deliverable are BECTRA analysis. The 2026 OECD proposals are identified as consultation material rather than adopted guidance.
1. OECD, *Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022*, Chapter VII: https://www.oecd.org/en/publications/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-2022_0e655865-en.html
2. OECD, 2026 public consultation on revisions to Chapter VII: https://www.oecd.org/en/events/public-consultations/2026/06/public-consultation-on-taxation-revisions-to-chapter-vii-of-the-oecd-transfer-pricing-guidelines.html
3. FATF, *Updated Guidance for a Risk-Based Approach to Virtual Assets and VASPs*, 28 October 2021, with its notice on later revisions: https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-rba-virtual-assets-2021.html
4. FATF, *Targeted report on Stablecoins and Unhosted Wallets — Peer-to-Peer Transactions*, 2026: https://www.fatf-gafi.org/en/publications/Virtualassets/targeted-report-stablecoins-unhosted-wallets.html
5. European Union, Regulation (EU) 2023/1113, including Articles 14–22: https://eur-lex.europa.eu/eli/reg/2023/1113/oj/eng
6. AMLA, 2026 consultation on ongoing monitoring of business relationships: https://www.amla.europa.eu/amla-consults-draft-guidelines-ongoing-monitoring-business-relationships_en
Comments