For recurring intragroup services, documentation needs to follow the activity from one period to the next. The contract sets the framework, while specific evidence should explain what was done, for whom and how the charge was calculated.
Preparing for a tax review means being able to explain the facts and find the documents supporting them. A clear process for requests and responses reduces confusion and helps the team exercise its rights on an informed basis.
Transaction records should explain both what the parties agreed and what actually happened. Contracts, invoices and evidence of performance are more useful when they provide a coherent explanation of the economic purpose.