Extract to table

Any such intercompany charges must comply with arm's-length standards under IRC Section 482 and the OECD Transfer Pricing Guidelines

• The fee breakdown among the three service categories (managed network services, ArcMesh platform license and maintenance, and professional services) must be maintained on all invoices and in all payment records

• The Canadian NOC service delivery must be addressed through appropriate GST/HST/PST provisions in the MSA

states creates significant multi-state sales and use tax considerations that must be addressed both contractually (in the MSA) and operationally (through proper invoicing, collection, and remittance procedures)

If ArcMesh is delivered as SaaS, the analysis must address the expanding patchwork of state SaaS taxation rules, which continue to evolve and may change during the five-year initial term of the MSA

The combination of Canadian-based service delivery (from the Winnipeg NOC) and Canadian-located service recipients (NAI's managed nodes) creates Canadian indirect tax obligations that must be addressed in the MSA