Intercompany Agreements for Transfer Pricing

Specialist legal support for multinational groups

If you are a Tax, Transfer Pricing, Finance and Legal professional, and you want to put in place appropriate Intercompany Agreements for a multinational group, then you have come to the right place.

You have probably already invested significant time and resources on updating the group’s transfer pricing policies – not an easy task. To get the most value from that investment, you need to ensure that those policies are supported by effective Intercompany Agreements. Not doing that would be like building a house and not finishing the roof.

This does not have to be complicated. But, like anything else, it needs to be properly planned and implemented. And it does not get easier if you put it off. In fact, it gets harder and more expensive, because then you can often find yourself trying to backdate arrangements in a hurry.

Make your transfer pricing more robust with clear and effective intercompany agreements

When you put in place appropriate Intercompany Agreements and related processes, you get the peace of mind of knowing that your transfer pricing policies are more robust. You can deal with any challenges more quickly and easily because:

  • You can provide written evidence of the supplies which are being made
  • You can provide written evidence of the terms of those supplies
  • You can show that similar supplies are being dealt with consistently across the group, and clearly identify the extent to which the terms of supply differ

Work with acknowledged, independent experts on Intercompany Agreements for transfer pricing

LCN Legal is one of very few law firms specialising in the implementation of effective Intercompany Agreements for transfer pricing. We don’t advise on tax, and we don’t carry out comparables research – so we are truly independent and our work does not overlap in any way with that of your transfer pricing team or external transfer pricing advisors.

Our team has contributed to the LexisNexis online resources on transfer pricing, as well was various other respected publications such as the Tax Journal, Transfer Pricing Week, Financial Director, Practical Law Magazine, Practical European Tax Strategies, International Accountant and Butterworths Journal of International Banking & Financial Law.

We also regularly run workshops, training sessions and teleseminars for major accounting firms, multinational corporates and financial institutions on Intercompany Agreements, international corporate structures and related legal issues.

Testimonials for LCN Legal

Our team has gained experience from working within blue-chip organisations such as KPMG, Baker & McKenzie, Linklaters and Accenture. We have advised FTSE100 and Fortune 500 companies on projects involving over £12.8 billion of assets. Here is a small selection of the testimonials provided for our work and our seminars:

I really like the format! It is very clear and easy to follow.
Can you teach our lawyers to write so clearly?
I wonder sometimes if they are being paid by the word.
Director, International Tax and Transfer Pricing, Fortune 500 and S&P 100 Company, commenting on template Intercompany Agreements created by LCN Legal

I found it refreshing to go through the technical challenges and best practice on unwinding entities, including project managing the process, with some highly skilled and experienced in-house tax and legal experts.
Lee Holloway, Head of Tax at Next plc

I worked with Paul Sutton for many years whilst he was at McGrigors / Pinsent Masons, in my role as Group Tax Manager of Sumitomo Electric Wiring Systems (Europe) Ltd (SEWS-E Ltd), and also for a period as SEWS-E Ltd Company Secretary. In this time I had extremely valuable assistance and advice from Paul, not only as regards general corporate law matters, but also particularly across a wide spectrum of legal aspects of SEWS-E Ltd group transfer pricing policies, implementation, inter-group agreements and legal compliance.
Martin Kinsey, Group Tax Manager
Sumitomo Electric Wiring Systems (Europe) Limited

LCN Legal’s publications and resources on Intercompany Agreements and transfer pricing

We regularly publish articles and materials on Intercompany Agreements and transfer pricing. This includes:

  • interviews with senior tax and transfer pricing professionals from organisations such as American Express, Deloitte, HSBC, Next, RELX (Reed Elsevier), Sandvik and Thomson Reuters.

You can access our free guides by clicking on the following links:

How we can help you

If you are a CFO or other in-house tax professional, we can provide different levels of support depending on your needs. This includes:

  • Facilitating internal, cross-functional workshops to get your project off to a good start
  • The LCN Legal ‘Toolkit’ for Intercompany Agreements, which includes template agreements as well as practical checklists and other legal and project management resources (see below for more information)
  • Reviewing and updating your existing intercompany agreements and processes
  • Designing and tailoring new template intercompany agreements for some or all of your intra-group supplies
  • Hands-on support to streamline your group structure, removing dividend blocks or dealing any other corporate restructuring matters

If you are a tax or transfer pricing adviser, or a provider of other transfer pricing solutions, we are delighted to work alongside you and complement the services you provide. Because we do not advise on tax or transfer pricing, we support and respect your relationship with your clients, with no conflict issues arising.

The LCN Legal Intercompany Agreements Toolkit

LCN Legal has created a ‘Toolkit’ specifically for Intercompany Agreements for Transfer Pricing. The toolkit which saves you hundreds of hours by giving you tried and tested template agreements documents to use as a starting point, and give you reassurance that your agreements which be consistent with international best practice.

The toolkit gives you the benefit of:

  • Access to the LCN Legal library of template intercompany agreements, which you can tailor for your group
  • An ‘Intercompany agreements implementation pack’ of practical checklists and worksheets to help you plan and implement your project
  • Telephone support from senior qualified lawyers who specialise in intercompany agreements

For more information, click here.

Contact us to arrange a free, confidential consultation

If you would like to have a free, confidential discussion about your needs and how we can help, email us at info@lcnlegal.com, or call us on +44 20 3286 8868.