Expert Resources

Take advantage of our free expert resources, written by the experts at LCN Legal, based on their practical experience of working with multinational groups and their advisers across the globe. If you are interested in these areas, you may wish to bookmark this page to check back regularly for new information.

Legal Resources

Briefing on how to create effective Intercompany Agreements for Transfer Pricing

Intercompany Agreements

Issue of Quoted Eurobonds to Related Parties – Preliminary Legal Information Request

Group Reorganisations

Special Report for Legal Counsel – OECD’s Transfer Pricing Guidelines (2017)

Intercompany Agreements

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Paul Sutton

HMRC’s Profit Diversion Compliance Facility – Private Discussion Group with Mark Carnduff

Paul Sutton Events & Seminars, Intercompany Agreements
Following HMRC’s announcement of the Profit Diversion Compliance Facility (PDCF), a number of multinational groups have received so-called ‘nudge’ letters from HMRC, encouraging them to consider registering for the facility. Still more groups have made unprompted disclosure, or are in the process of preparing to make disclosure. On 27 June 2019, …
Xiaofang Sutton

The five women who inspire me the most

Xiaofang Sutton Personal Blog
Happy International Women’s Day everyone! Wherever you are, whoever you are (daughter, mother, sister, mother of daughters and father of daughters etc), today is not only a day to celebrate women and girls worldwide, it is a day to celebrate equality, fairness and humanity. We’ve been on the planet for a long time and women have only recently been …
Xiaofang Sutton

What Jim Rohn would say to a Mum Entrepreneur?

Xiaofang Sutton Personal Blog
My husband and I have this habit of asking the question of what a famous successful public figure would say or do if he/she was in our situation. Last week, I was having one of those days where I was trying to finish work on time and get to the bottom of that never ending to do list, but I didn’t. Everything after that was just a blur for me; I rushed …
Paul Sutton

China APA stats

Paul Sutton Intercompany Agreements
Just in case you’re interested in these things: last month, China’s State Administration of Taxation (“SAT”) published its annual report on Advance Pricing Arrangements (APAs). The report covers the period from 2005 to 2017. According to the report, China’s APA programme still deals primarily deals with inbound MNE applicants. Here are the …
Paul Sutton

HMRC Announces New Profit Diversion Compliance Facility

Paul Sutton Intercompany Agreements
On 10 January 2019 HMRC announced a new Profit Diversion Compliance Facility (PDCF) to encourage multinational enterprises (MNEs) to make voluntary disclosures about mistakes or failures to notify in respect of profits diverted from the UK. Full details of the announcement can be found here. Why have HMRC announced a new Profit Diversion Compliance …