Blog

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.

Transfer Pricing Methods: A Practical, 2026 Guide for In‑House Tax and Legal Teams

23 May 2026   Paul Sutton

Transfer pricing method selection remains one of the most contested areas in cross‑border tax. Although the OECD Transfer Pricing Guidelines (TPG) emphasise the “most appropriate method to the circumstances of the case” standard rather than a strict hierarchy, tax authorities worldwide are increasingly assertive in pushing for traditional transaction methods — particularly the Comparable Uncontrolled…

Enterprise AI in Practice: Lessons from Our Conversation with Candy Liu, Strategic Global Account Lead at Microsoft

23 April 2026   Paul Sutton

In the latest episode of the LCN podcast, we had the privilege of hosting Candy Liu, Strategic Global Account Lead at Microsoft. Candy advises some of Microsoft’s 200 global strategic accounts, which means her role gives her a unique vantage point on what AI adoption really looks like inside the world’s largest enterprises. This blog…

Transfer Pricing Audit Readiness: Are You Really Prepared?

23 April 2026   Paul Sutton

At a recent LCN roundtable, one question dominated the transfer pricing conversation: how to prioritise action to achieve tax and transfer pricing audit readiness – given the amounts at stake, and the range of inter-related factors? To help answer that, we introduced the Transfer Pricing Health Wheel, a practical self-assessment tool designed to spotlight strengths…

Identifying Intangibles: Lessons from Our Webinar with Donal O’Connell

29 March 2026   Paul Sutton

In a recent webinar, LCN hosted Donal O’Connell, former Director of IP at Nokia and a highly experienced practitioner in global IP management, for a deep dive into one of the most persistent blind spots in transfer pricing: how to identify intangibles in the first place. Transfer pricing professionals are well-versed in DEMPE analysis. The…

The Transfer Pricing Environment in Africa: what multinationals need to know


29 March 2026   Paul Sutton

Africa’s transfer pricing landscape has changed more in the past five years than in the previous twenty. That was the clear message from LCN’s recent webinar with Cabrini McCarrick and Rajnish Singh of Regan Van Rooy, international tax advisers based in South Africa, Mauritius, Ireland and the UK. For many multinationals, Africa still feels like…

How Intercompany Agreements Shape Transfer Pricing and Customs Compliance

21 February 2026   Paul Sutton

Transfer pricing is rarely the sole driver of intercompany agreements (ICAs) or group legal structures. It is one of several critical factors that must be weighed. ICAs are the factual anchor for a group’s dealings across tax, customs, regulatory, and governance domains, as the recent Tauritus case demonstrates in the context of VAT and customs…

Intercompany Agreements

Why Legal Operating Models Matter More Than Ever

21 February 2026   Paul Sutton

Most multinational groups operate with complex webs of legal entities, cross-border roles, intercompany flows, and regulatory obligations, but very few have a single, coherent framework that explains how all of this is supposed to work. That gap is increasingly becoming a real source of tax, governance and operational risk. Tariff escalation, diverging U.S.–EU approaches to…

Intercompany Agreements

Transfer Pricing and Blocked Income: Lessons from 3M’s Royalty Dispute

24 October 2025   Paul Sutton

In a landmark ruling that reshapes the boundaries of U.S. transfer pricing enforcement, the Eighth Circuit Court of Appeals has sided with 3M in its long-running dispute with the IRS over “blocked income.” The court reversed a $24 million adjustment, holding that U.S. tax law cannot compel recognition of royalty income that a taxpayer is…

Intercompany Agreements

Join our inner circle

Sign up for our free email newsletter

Receive weekly practical insights on how to keep intercompany agreements and cross-border corporate structures tax-audit ready and transaction ready.