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.

Paul Sutton

Not an article about transfer pricing

This post is not about transfer pricing. It’s about what the transfer pricing and tax community has enabled us to give. We’ve wanted to get involved in donating books for schools for a while now. Partly, this was inspired by my wife and co-founder Xiaofang’s experience of growing up in China – and the importance of helping children (and especially …
Paul Sutton

The karma of Transfer Pricing

What goes around, comes around. Every action has an opposite reaction. Every legal right is matched by a corresponding legal obligation. This is true in the area of international group structures and transfer pricing policies, as it is in every other area of life. For example, a distributor may be intended for TP purposes to be exposed to limited risks …
Paul Sutton

Swimming pools and allocation keys

In the context of transfer pricing, an allocation key is simply a way of apportioning the recharge of centrally incurred cost across multiple beneficiaries. A typical example is head office services such as finance, accounting, tax, legal, HR, IT services etc, where the costs involved do not directly relate to a specific benefitting entity. Typical …
Paul Sutton

What if BMW designed transfer pricing documentation?

This is a picture of the BMW R32 motorbike, which was the first motorbike to be produced under the BMW brand. You might be surprised to know that it first went into production in 1923, despite not looking out of place decades later. The R32 introduced a number of innovations, including a boxer-twin shaft drive layout which is still in use now. (‘Boxer’ …
Paul Sutton

Can a single clause in an intercompany agreement make a 20% difference to the pricing of a controlled transaction?

In real life, a single clause (or even a single word) in a legal agreement can make a huge difference to the commerciality of an arrangement. Exclusive vs non-exclusive licences. Recourse vs non-recourse factoring. One month vs 12 month subscription terms. Overdrafts repayable at will vs term loans with no right of prepayment. Intercompany transactions …