We’ve decided to create a new version of our book: ‘Intercompany Agreements For Transfer Pricing: A Practical Guide’. It was first published in March 2019, and we’d like to reflect changes in transfer pricing governance and in the commercial environment since then. We also want it to much more closely reflect the content of our flagship training course. And we’re going to introduce a new look, with much greater use of graphics and charts.
Before we start work, we’d like to give you an opportunity to help shape the contents of the new book. If you have read the existing version, or taken the training course, what did you find particularly useful? On the other hand, is there anything you think we should leave out? More generally, which of the legal aspects of transfer pricing do you find most challenging or most likely to create problems for taxpayers?
To help you, here is the currently planned content:
Glossary
Introduction
- Purpose of the book
- How to use the book
Background concepts
1. Corporate structures for multinational groups – key elements
2. Corporate governance, legal entity and contract fundamentals
3. Transfer pricing fundamentals
4. Intellectual property and intangibles
5. Contractual allocation of risk and reward
Practical application
6. General principles regarding the form and content of intercompany agreements
7. Pricing clauses
8. Other clause types and drafting considerations
9. High level scoping of intercompany transactions and interpretation of transfer pricing policies
10. Reviewing intercompany agreements for alignment with TP policies
11. Managing the implementation and ongoing maintenance of agreements
Specific transaction types
12. Introduction to discussion of transaction types
13. Transactions involving services, including:
- Central support services
- Local support services
- Contracting services
- Lead contractor support services
14. Transactions involving goods
- Supply of goods
- Contract manufacturing
- Toll manufacturing
15. Distribution and reseller arrangements
- Distribution
- Sales agents and commissionaires
16. Intellectual property licenses and franchise arrangements
- IP licences
- Franchises
- R&D services
17. Profit split and cost sharing / cost contribution arrangements
18. Loans, cash pooling and other forms of financial support
- Loan agreements
- Loan note instruments
- Cash pooling arrangements
- Guarantees and guarantee fees
Appendix
19. Checklists
- Stakeholders in the management of intercompany agreements
- Goods
- Services
- IP
- Loans
- Cost sharing / cost contribution arrangements
If you have any thoughts or suggestions, please do get in touch and let us know. We will consider all of them when we decide on the content for the new book.
Thank you very much in advance.
Free insights
Receive weekly practical insights on how to keep intercompany agreements and cross-border corporate structures tax-audit ready and transaction ready.
