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Price setting vs outcome testing in Germany and Poland

Paul Sutton Intercompany Agreements

The following article has been kindly contributed by Dr Harold McClure, a New-York based economist who has over 25 years of transfer pricing experience. Dr. McClure received his Ph.D. in economics from Vanderbilt University in 1983 and began his transfer pricing career at the IRS. He later worked at several Big 4 accounting firms, Law and Economics …

The two types of profit split arrangements in transfer pricing

Paul Sutton Group Reorganisations, Intercompany Agreements

In commercial relationships as in intra-group structures, there are two types of profit split arrangements. In both types, the participants to the arrangement may make (a) an up front contribution of cash or assets, and/or (b) ongoing contributions of services. The distinction is in the nature of the interest which each participant receives. A Type …

Video Interview: Update on HMRC’s Profit Diversion Compliance Facility

Paul Sutton Intercompany Agreements, Interviews

Many thanks to Ken Almand for sharing his insights and updates on HMRC’s Profit Diversion Compliance Facility (PDCF), including his commentary on HMRC’s webinar last week. Questions we discussed included: * Did HMRC’s webinar on 6th October tell us anything new? * What have we learned from our experiences with the PDCF so far? In which situations …

Winners: Excellence in International Legal Services

Paul Sutton Intercompany Agreements, LCN Updates

My colleagues and I were humbled that our firm was shortlisted for the Law Society’s 2020 Excellence Awards, alongside firms like Baker McKenzie, Dentons, King & Spalding, Reed Smith, Societe Generale and Travers Smith. We were even more humbled that we actually won last week, in the category of ‘Excellence in International Services’. A result …

Preparing for Transfer Pricing Audits: Bayer’s Battle with the Canadian Revenue Agency

Paul Sutton Intercompany Agreements

The following article is part of a series of case studies and articles which have been kindly contributed by Dr Harold McClure, a New-York based economist who has advised in the area of transfer pricing for many years. Action 13 of the Base Erosion and Profit Shifting project requires large multinationals to prepare a Master File along with Country-by-Country …

Building something that stands up

Paul Sutton Intercompany Agreements

Apparently, the IRS believes that the quality of transfer pricing documentation may have declined. (See its FAQ guidance issued in April this year.) They believed it necessary to remind practitioners that TP documentation needs to be consistent with risk allocation in intercompany agreements. Isn’t that like having to remind a glazier that the glass …

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Expert Resources

Price setting vs outcome testing in Germany and Poland

The two types of profit split arrangements in transfer pricing

Video Interview: Update on HMRC’s Profit Diversion Compliance Facility

Winners: Excellence in International Legal Services

Preparing for Transfer Pricing Audits: Bayer’s Battle with the Canadian Revenue Agency

Building something that stands up

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