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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.

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The arm’s length principle: fact or fiction?

Paul O’Regan

We hope you enjoyed our recent interview with Philippe Paumier. We found it very thought-provoking, and in fact we’d like to share some of those thoughts with you here. The starting point is Philippe’s statement: “TP is a construction. It’s a theoretical construction. The very basic and fundamental point of transfer pricing is that parties have to behave […]

Group Reorganisations

Intercompany Agreements

Your Q&A with TP professionals at Michelin, Procter & Gamble and Verizon

Paul O’Regan

We are Gold Partners of this year’s TP Minds West Coast conference on 8th and 9th December. As part of that, Paul Sutton will be chairing a panel discussion on ‘Practical Approaches to Avoid an Intercompany Agreement Disaster’. The panel has a stellar line-up: Adnan Begic (Head of Transfer Pricing, Asia-Pacific, Michelin), Kurt Wulfekuhler (Director, Verizon) and Jason Wiegand (Transfer Pricing Lead, Procter & Gamble). […]

Intercompany Agreements

The LCN Interview: Philippe Paumier

Paul O’Regan

Philippe Paumier is a transfer pricing expert with over 20 years’ experience, most of it acquired as an in-house expert in major multinationals. In 2019 he founded VECTOR TP, which combines in-house know-how on transfer pricing with extensive international practical experience. Tell us more about VECTOR TP: what makes it different? I started […]

Interviews

Intercompany Agreements

New Austrian TP guidelines: would your intercompany agreements pass the ‘prudent business manager’ test?

Paul O’Regan

Austria recently updated its transfer pricing guidelines in order to keep them in line with OECD guidance, among other reasons. It was the first such change for 11 years. This helpful article by Iris Burgstaller on the MNE Tax website looks in detail at what has changed, and one thing in particular jumped out for us. The […]

Intercompany Agreements

The LCN Interview: Rebecca Flanagan

Paul O’Regan

Rebecca has just joined the LCN Legal team as a Director. She brings a lot of experience of advising on M&A and group reorganisations. How did you become a specialist in group reorganisations? I did my training contract at Clifford Chance, and I worked there for about four years post-qualification. Then I moved to […]

Group Reorganisations

Interviews

Intercompany Agreements

The LCN Interview: Adrian Camara

Paul O’Regan

Adrian Camara is co-founder and CEO of Athennian. The company provides a cloud-based legal entity management system, used by law firms and in-house teams to manage complex corporate groups. Launched in 2017, the business has grown rapidly and now has 89 employees across its HQ in Calgary, Canada, and other offices in North and South […]

Interviews

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