Here at the LCN World Headquarters, we’re getting excited about running a webinar tomorrow on Intercompany Agreements (ICAs) for TP compliance. It will be for a team of TP advisers in China. One of the points we’ll be covering is why the quality of ICAs is often so poor – even for large multinationals – when the OECD’s TP guidelines clearly …

We have the luxury of reading a lot of Transfer Pricing reports, including master files and local files for BEPS compliance. We’re usually reading them with a specific purpose: to understand the structure of the intercompany supplies, and translate that structure into appropriate legal agreements. However, we also get to appreciate the reports as …

In honour of LCN Legal’s imminent 5th anniversary, here’s a list of 5 things people often forget when it comes to putting in place the Intercompany Agreements (ICAs) which multinational groups need for Transfer Pricing compliance: 1. Intercompany agreements (ICAs) are essentially forward-looking: they are promises to act in a certain way …

As you probably know, the OECD has recently released a non-consensus discussion draft on the Transfer Pricing treatment of financial transactions between associated enterprises, under the BEPS project. You can download the discussion draft here. The types of arrangements considered include intra group loans, guarantees, hedging, cash pooling and captive …

  This was one of the discussion points which came up at the seminar we co-hosted with the Thomson Reuters ONESOURCE team last month. The focus of the seminar was the practicalities of managing Intercompany Agreements for TP compliance. Intercompany agreements (ICAs) don’t replace or override functional analysis. The two go hand in hand. On a …