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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.

Carbon net zero: can you be more helpful than Bill Gates?

Paul O’Regan

We’re sure you agree that huge, eye-catching changes will only be part of the solution to the climate crisis. It is just as important that small businesses and individuals do what they can too. At LCN Legal – without looking for any praise in return – we want to do our bit. But exactly what […]

LCN Updates

The Pfizer Panama decision: A compelling case for an ICA healthcheck?

Paul O’Regan

I’d like to draw your attention to a Resolution of the Administrative Tax Court of Panama of 9 July 2021, which set a precedent for transfer pricing in Panama. Many thanks to Miguel Medeiros at Sol Petroleum for highlighting the case and for sharing his thoughts on it. As always, we’re extremely grateful for the feedback we […]

Intercompany Agreements

Results of our consultation: transfer pricing risks associated with frequency of intercompany invoicing

Paul O’Regan

Every Monday we send out an email with insights, guidance and views on the legal implementation of transfer pricing for multinational groups. (If you don’t subscribe to it, just scroll to the bottom of this page and fill in the box.) A couple of weeks ago we looked at the frequency of invoicing of intercompany […]

Intercompany Agreements

The LCN Interview: Adnan Begic

Paul O’Regan

  Adnan Begic is Head of Transfer Pricing for Michelin Asia-Pacific. A highly experienced TP expert, he has also worked in Big Four firms in New Zealand and Singapore.   How did you first get into transfer pricing? To be honest, it was completely by chance. My university background is typical: MBA, focusing on corporate […]

Interviews

Does frequency of invoicing matter in intercompany transactions?

Paul Sutton

This week we’d like to ask you for your insights. When we work alongside TP professionals to create intercompany agreements for multinational groups, we typically focus on the four main areas of alignment: 1. Delineating the transaction through the parties’ functions and obligations 2. Allocation of risk 3. Ownership of intangible assets 4. Pricing, including […]

Intercompany Agreements

When is an agreement not an agreement?

Paul Sutton

I’d like to share with you a comment that I saw recently, from a TP adviser in relation to a draft intercompany agreement. The agreement – which was not drafted by us, by the way – concerned software development services charged on a cost-plus basis. The comment was: “The margin should be defined as arm’s […]

Intercompany Agreements

How can you cross the ‘technology gap’?

Paul Sutton

For anyone who works in professional services, the product you’re selling exists almost entirely in your head. People pay you primarily for your knowledge, insight, communication skills and so on. But how can you harness them to best effect? Modern technology creates countless opportunities to do that, but many professional advisers (wrongly) believe that they […]

Interviews

The LCN Interview: Dorna Moini

Paul O’Regan

Dorna Moini is CEO and co-founder of Documate, a document automation platform that allows lawyers to create documents and build client-facing legal applications without needing any skill in coding or software engineering. Documate is also a key supplier to LCN Legal: we use Documate’s platform in many parts of our business, including intercompany agreements for […]

Interviews

Making comparability transparent

Paul Sutton

One of the key functions of intercompany agreements is to be transparent as regards key matters such as risk allocation, compensation (pricing), and ownership of intangible assets. What does ‘transparent’ mean in this context, and why does it matter? Transparency requires that intercompany agreements should be easily understood by the reader, no matter who that […]

Intercompany Agreements

Are you going to amputate the wrong leg? Webinar Registration

Paul Sutton

According to the OECD’s TP Guidelines, analysing the contractual allocation of risk in intracompany agreements (ICAs) is the second step for pricing risk, after you’ve identified which risks are relevant. Comparables aren’t comparable, unless the risk allocation is at least similar. This makes complete sense. In our day-to-day lives, we all instinctively factor in contractual […]

LCN Updates

Live Workshop for TP Advisers: Scoping Local Sales Entities

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In our experience, MNEs screw up their arrangements involving local sales entities more often than any other intercompany transaction type. We’re talking here from the perspective of legal implementation of TP policies. Why does this matter? Because the transaction will fail at Step 4 of the OECD steps for analysing risk and pricing transactions, since […]

LCN Updates

The No. 1 Question for Assessing How Well an MNE is Legally Implementing its Transfer Pricing

Paul Sutton

One of the blessings of the ‘new normal’ for us, is that we’ve been able to sponsor and participate in a far wider range of TP conferences than would otherwise have been the case – over the last 12 months, this has included TP Minds Australia, Asia, West Coast, Canada and Americas, as well as […]

Intercompany Agreements

Workshops – bring together representatives of the key in-house functions involved (e.g. tax, finance, legal, compliance and risk).

Paul Sutton

I’ve lost count of the number of transfer pricing articles I’ve read over the last couple of months which tell their readers to “review your transfer pricing policies” and “update your intercompany agreements” in the light of recent economic circumstances. This is undoubtedly good advice. The problem is that few TP or tax professionals know […]

LCN Updates

Coca-Cola’s US$ 12 billion IP mistake

Paul Sutton

The following article first appeared in IP Briefs, the journal of the South African Institute of Intellectual Property Law. One might think that an organisation with one of the most recognised and valuable brands in the world, founded in 1892, might be a well-oiled machine when it comes to managing its intellectual property rights. And […]

Intercompany Agreements

New Vacancy at LCN Legal: Team Administrator

Sonia Polden

Summary of new vacancy: team administrator LCN Legal is seeking a superstar team administrator to join our dynamic and ambitious firm. We offer a unique combination of benefits: The ability to work from home (or any other suitable location). A friendly and supportive culture. The opportunity to support the growth and development of an award-winning […]

LCN Updates

Managing the TP aspects of M&A integration: TP Masterclass interview with Adnan Begic

Paul Sutton

We recently began a new series of Transfer Pricing Masterclass Interviews. The first was with Adnan Begic, a hugely experienced and widely admired expert on the subject, who is Head of Transfer Pricing Asia-Pacific for the Michelin group. The starting point for the interview was the fact that traditional TP due diligence on a target group […]

Interviews

TP Audits – Get Your ‘Hard Hat’ at TP Minds International!

Paul Sutton

It’s TP Minds International this week, and I’m looking forward to contributing to a panel discussion on ‘Managing TP Audits and Defending Your TP Position’ on Wednesday 16th at 13.05 BST. The discussion will feature Catherine Harlow, Head of TP at AstraZeneca and Kurt Wulfekuhler, TP Director at Verizon Communications, and will be chaired by Anton Hume, […]

LCN Updates

New vacancy at LCN Legal: Mid level / senior corporate lawyer

Paul Sutton

Summary of new vacancy: mid level / senior corporate lawyer LCN Legal is seeking a mid level / senior corporate solicitor / associate to join our dynamic and ambitious team. We offer a unique combination of benefits, including a clear route to partnership: Direct exposure to a diverse range of multinational corporate groups and household […]

LCN Updates

New TP documentation rules from HMRC could increase the compliance burden, especially for SMEs

Paul O’Regan

Our partner Ivan Hanna recently spoke to the International Tax Review for an article about new TP compliance rules that HMRC is planning. These could have implications for many businesses, particularly smaller ones that were previously exempt. As Ivan points out, the 30-day deadline to produce a master and local file on request means that […]

LCN Updates

How should TNMM / CPM arrangements be implemented in ICAs?

Paul Sutton

Some TP methods – specifically, the cost plus method – imply a specific drafting structure for pricing clauses in intercompany agreements (ICAs). Others do not. Take for example, the Transactional Net Margin Method (TNMM), aka the Comparable Profits Method (CPM). This method may suggest a drafting approach based on the relevant profit or margin, or […]

Intercompany Agreements

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