We are specialists in managing the legal implementation of transfer pricing policies and group reorganizations. We design, implement and maintain intercompany agreements to support compliance, reduce risk and maximize shareholder value.
LCN supports multinational groups by bringing a global and cross-functional approach to the legal design and maintenance of intercompany agreements, corporate structures and transactions.
Maintaining tax-audit-ready and transaction-ready agreements is essential for managing tax risks for international groups. Solid legal foundations and streamlined transaction flows enhance shareholder value and reduce compliance costs.
Reduce risks arising from lack of legal substance in intercompany transactions and failure to implement transfer pricing policies legally.
Transaction-ready and fit-for-purpose corporate structures with clear ownership of intangible assets.
Eliminate unnecessary complexity and wasted management time caused by misalignment between tax compliance policies and legal structures.
Protect legal entity directors by documenting the commercial rationale for intercompany transactions, and demonstrating that directors have complied with their fiduciary and regulatory duties.
Comprehensive Legal Solutions for In-House and Advisory Teams
We ensure that your group’s transfer pricing documentation for each financial year is backed up by robust, OECD-compliant intercompany agreements and corporate structures. Avoid risks of unnecessary double taxation and wasted costs caused by defective legal implementation of TP policies, and TP documentation which does not match the legal fact pattern.
We enable leading tax and transfer pricing advisers to provide better client outcomes. Our leading expertise in designing and managing the legal implementation of transfer pricing policies enables you to offer a joined-up, higher value service.
We follow a proven approach to ensure intercompany agreements and legal structures are aligned with transfer pricing policies, tax objectives, regulatory requirements and economic substance.
Identify key intercompany transaction types clearly.
Review fact patterns and existing agreements.
Create agreements to meet the requirements of the OECD Transfer Pricing Guidelines.
Finalize agreements, taking into account the needs of the wider stakeholders.
Brief directors, arrange signatures and create an audit-ready archive.
Fix gaps and defects in your intercompany agreements. Prompt action mitigates tax risks for current periods, and ensures that those risks do not extend to future periods.
Expert Management of Intercompany Agreements and Legal Structures
Our expertise in international best practices ensures compliance and reduces tax risks.
We save you significant time by giving you clear direction and hands-on support in the highly specialist area of legal implementation of transfer pricing compliance.
We streamline intercompany agreements and corporate structures, reducing complexity, risk and transaction costs.
We are recognized educators in the legal implementation of transfer pricing policies.
We consider the needs of wider stakeholders - not just transfer pricing - to minimize risks and optimize value for the group concerned.
We maintain agreements in a tax-audit-ready central archive so that they can be produced quickly when required to respond to tax enquiries and due diligence information requests.
We work with Fortune 500 companies and scale-ups.
We work collaboratively with tax and transfer pricing professionals to help provide clients with better outcomes.
We are trusted by leading tax and transfer pricing advisers and by corporates with combined annual revenues of over US$160 billion.
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