• +1 747 212 0206
  • +44 20 3286 8868
  • +86 21 2052 0623


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.

Transaction pairs: the basic unit of transfer pricing

26 May 2023   Paul Sutton

Before you can write ICAs, you need to know what the relevant transactions actually are. As far as I know, we at LCN Legal are unique in the world of transfer pricing. We are lawyers who specialise in the legal implementation of TP, but we don’t advise on TP itself. This means that every year…

Intercompany Agreements

Internal carbon pricing: an intercompany legal perspective

21 May 2023   Paul Sutton

The TP treatment of ICP: corporate law fundamentals apply Internal carbon pricing (ICP) is not new – companies such as Microsoft are reported to have introduced internal carbon fees over 10 years ago. ICP policies are designed to factor in the estimated cost of carbon dioxide emissions into business decisions. Such policies can take a…

Intercompany Agreements

Amgen litigation: TP risks can extend far beyond tax compliance

15 May 2023   Paul Sutton

The Amgen class action law suit shows the potential impact of TP risks on M&A On 13 March 2023, a claim was filed against Amgen Inc, the biopharmaceutical group, as part of a proposed class action by investors. It’s an interesting example of how the management of TP risks can have far wider implications than…

Intercompany Agreements

New podcast episode: how to healthcheck your ICAs

28 April 2023   Paul O’Regan

The latest episode of our podcast is now out. In it we discuss how to review intercompany agreements to ensure alignment with TP policies. Discrepancies between a group’s intercompany agreements and the transactions as described in its TP documents are an ‘easy win’ for tax authorities when seeking to raise challenges. And more fundamentally, transfer…

Intercompany Agreements

Embedded Royalties for Sales of Pepsi Concentrate in Australia

26 April 2023   Guest Author

This is a guest post by Harold McClure, a New York City-based independent economist with 26 years of transfer pricing and valuation experience. (One of several that he has written for us.) Here he looks in detail at a case currently ongoing in Australia, Pepsi, in the light of a 2020 case involving Coca-Cola.   …

Intercompany Agreements

A brief report from TP Minds Americas 2023

26 April 2023   Paul Sutton

Five key themes from TP Minds Americas My colleague Leiza Bladd-Symms recently represented LCN Legal at TP Minds Americas, a key industry event that took place in Miami. Here’s a very brief report of five key themes from the conference: 1. The increasing importance of sustainability and ESG (Environmental, social, and corporate governance) in transfer…

Intercompany Agreements

The 3M ‘blocked income’ TP litigation, and the impact of legal restrictions on TP policies

24 April 2023   Paul Sutton

In February, the US Tax Court ruled in favour of the IRS in a transfer pricing case involving 3M (3M Co. v. Commissioner, 160 T.C. 3). The case will have important implications for ongoing TP litigation and historic tax positions. It involved legal restrictions (as opposed to tax restrictions) on the payment of royalties by…

Intercompany Agreements

Podcast transcript: ongoing TP litigation in Australia, with Andy Bubb

14 April 2023   Paul O’Regan

The following transcript has been lightly edited for clarity. The original interview can be heard on The LCN Legal Podcast here. Paul Sutton: Hi Andy. It’s an absolute pleasure to have you on this podcast. So many thanks indeed for sparing the time. We’re going to talk about three cases today: Pepsi, Singtel and Mylan….


Free Guide: Effective Intercompany Agreements for TP Compliance