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HQ charges · 03 Editorial guide

HQ charges & service fees

Banks test substance on HQ charges. A management-fee label is not the file.

First job Separate a genuine service payment from a disguised dividend before the bank pack.

Start here

Decision railentities and relationship → actual service → contract and pricing → delivery evidence → tax and invoice → bank and payment file
See routing facts

Start here

Key considerations

The first questions are about urgency, governance and preservation — before collection expands or interviews begin.

  1. What service was actually performed?
  2. Is there a contract and invoice trail?
  3. Has this payment been rejected before?

Direct answer

What this page decides

Owner
02

A cross-border headquarters charge or service fee should be supported as a real service payment before the bank pack is assembled. Identify the payer, recipient, relationship, service, delivery evidence, pricing method, tax and invoice treatment, contract, approval path and currency flow. Reconcile the commercial substance with accounting entries and the requested remittance. This page organises that record; it does not approve deductibility, transfer pricing, withholding, foreign-exchange processing or bank acceptance.

At a glance

Which fact changes the next route

Use the fact that changes ownership or urgency to decide the next move.

Facts that change the next investigation route
QuestionWhy it mattersNext route
What service was actually received?A label such as management fee does not establish substance or benefit.Describe deliverables, personnel, period and business use.
How was the charge calculated?Allocation keys, mark-ups and pass-through costs need a traceable basis.Reconcile the invoice to the pricing model and underlying costs.
Do contract, tax and books align?Inconsistency can delay bank review and create tax questions.Cross-check agreement, invoice, filings, ledger and payment request.
Is this distinct from a dividend or royalty?Different payment characterisations follow different evidence and processing routes.Document why the payment matches the performed service.

Scope

What this page owns — and what it does not

This page covers entity relationships, service substance, contract, delivery evidence, pricing, accounting, tax documents and remittance preparation.
Royalties, cost-sharing, dividends, loans and reimbursements should be classified and analysed separately.
Not decided herearm's-length result, deduction, withholding, permanent establishment, invoice validity, FX eligibility or bank approval.

Practical workflow

Action, evidence, legal gate, output

Practical workflow
ActionDocuments / evidenceLegal gateOutput
Map parties and paymentGroup chart, registrations, accounts and proposed payment pathConfirm payer, beneficiary and relationshipEntity and funds-flow map
Evidence the serviceContract, work product, personnel, time and benefit recordsShow delivery to the paying entityService evidence index
Reconcile the chargePricing policy, allocations, cost base, invoice and ledgerExplain method and period consistentlyCharge calculation file
Assemble payment supportTax records, approvals, bank forms and prior correspondenceCheck current bank and authority requirementsRemittance pack

Documents

What to gather before the next call

These items help clarify the file; they are not a legal requirement list.

Documents to gather before instructing counsel
ItemWhy neededWho holds itRisk if missing
Intercompany service agreementDefines service, parties, period and pricingPayer and recipientThe invoice is unsupported or outside scope
Delivery and benefit evidenceShows commercial substanceService teams and recipient businessGeneric group activity is charged without a recipient link
Pricing, tax and payment reconciliationConnects calculation, books and remittanceFinance, tax and bank teamsAmounts or characterisation differ across documents

Common failure points

Where files usually break

  1. Using a generic agreement without proof of delivered services.

  2. Applying an allocation key that cannot be reconciled to source costs.

  3. Treating bank processing as proof of tax or transfer-pricing compliance.

Decision map

Keep the question bounded.

  1. Show the serviceWhat was done, by whom, for whom.
  2. Show the paperContract, invoice, tax overlay at a high level.
  3. If rejectedUse the blocked-payment clinic with the bank’s reasons.

Curated resources

Open the asset that matches this job.

Helpful to prepare

Facts that make the next conversation clearer.

These items are orientation aids, not a legal requirement list.

Service description in one sentencePaying entity and overseas affiliateWhether a prior rejection exists

Counsel hand-off

What to bring when you instruct

Bring the group and ownership chart, entity details, intercompany agreement, service description, work product and personnel evidence, pricing policy and calculations, underlying cost records, invoices, ledger entries, tax documents, internal approvals, bank correspondence and proposed funds flow.

Local context

Add the city when the bank’s practice changes.

Onboarding packs and SAFE handling vary by bank and city after the national FX route is identified.

Open city and province guides

Counsel hand-off

Need banking and FX counsel?

This hub organises payment routes and bank packs. It does not move funds, instruct a bank or replace the tax certificate on your facts.

Find banking & FX counsel

Submit an initial enquiry

Need qualified counsel?

Move carefully. Move with a record.

Use the portal to identify counsel for this practice and related China-side issues.