An international group consists of company A at the top and the two most important holdings B and C. All three companies render management services to their respective downstream companies charged at cost plus method. Taking this construction as their starting point, Roland Macho and Norbert Schrottmeyer first explain the difference between non-chargeable shareholder costs and chargeable services. Subsequently, they deal with the question whether companies A and B may be regarded as “shareholders” rendering non-chargeable services to downstream companies, and, if so, whether company A at the top must be charged with these costs. Eventually, they examine the tax treatment of shareholder costs.