The LCN Legal Podcast artwork

2 February 2023

Episode 1: Target Margin arrangements

Paul Sutton and Paul O’Regan discuss Target Margin arrangements, including when they are suitable, the options when drafting the intercompany agreements, and some common traps to avoid.

Target Margin is a frequently used transfer pricing model, and one which particularly lends itself to limited risk distribution arrangements. LCN co-founder Paul Sutton discusses the implications in detail.

  • When Target Margin arrangements are most likely to be suitable
  • The two main options when drafting the pricing clause of the ICA, and how to choose which one to use
  • The importance of looking at the transaction from both a TP perspective and a legal one, and then reconciling the two
  • Common mistakes, and how to avoid them

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