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 …

  If you want an antidote to gloom-and-doom reporting and the idea that global civilisation is in decline, you should read the book “Factfulness” by Hans Rosling, his son Ola Rosling and his daughter-in-law Anna Rosling Rönnlund. One of the book’s central messages is how outdated and inaccurate our view of the world is, on matters as fundamental …

If, like me, you’re a student of international corporate structures, you’ll like this interview with Edward Zeng. Edward is the Shanghai-based Senior Partner of HanSheng Law Offices, and the interview focusses on the “aggressive and comprehensive” approach of Customs officials in China, and the role of Intercompany Agreements in helping multinational …

I am delighted to confirm that Thomson Reuters’ will be hosting a webinar on Tuesday 19 June. The focus of the webinar is Intercompany Agreements for Transfer Pricing compliance, and sharing market insights as to how multinational groups can ensure that their Intercompany Agreements meet the necessary requirements. We are honoured to be the guest …

I would like to invite you to join an exclusive morning seminar at Thomson Reuters’ London headquarters in Canary Wharf on Thursday 21 June. Click here to register. The focus of the seminar is Intercompany Agreements for Transfer Pricing compliance, and sharing market insights as to how multinational groups can ensure that their Intercompany Agreements …