One of the interesting things about intra-group licensing of intellectual property and intangibles, is how it’s often inextricably linked with related transactions such as the sale of goods. This can create customs duties risks, which need to be managed alongside transfer pricing compliance and the group’s intellectual property protection …

How long is arm’s-length? This issue came up at a seminar on intercompany agreements hosted by Thomson Reuters Onesource at their Canary Wharf headquarters last Friday, at which I was guest speaker (thank you Sally, Amy, Dickson and Chris!). It’s a point we feel very passionate about and obviously we’re not doing enough to get the message out. …

We are delighted to feature this article, which has been kindly contributed by Harvey Lee, Senior Partner at Shanghai Kingfaith Consulting Co. Harvey’s contact details can be found at the end of the article. The payment of royalty and license fees by a Chinese subsidiary to its foreign parent company is a common feature of transfer pricing (TP) arrangement …

The treatment of implicit and explicit guarantees is one of the issues raised in the OECD’s discussion draft paper on financial transactions, which was released for comment in July this year. The discussion in section D of that paper mainly relates to loans made by an independent third party to a group company, and the pricing of guarantee fees which …

I’m hugely excited to be a guest speaker at a seminar hosted by Thomson Reuters at its London headquarters in Canary Wharf on Friday 30 November. The event will be from 09:30–12:00 noon GMT, and the subject of the seminar will be “Intercompany Agreements – Bringing together Tax & Legal.” We’ll look to address some of the following …