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New for 2020: Document automation tool for creating Loan Note Instruments to document related party debt

Paul Sutton Intercompany Agreements

A very Happy New Year to you! As part of the ongoing development of our ‘fast track’ service for intercompany agreements, we have released a new automation tool, which is to create a loan note instrument to document related party debt. This tool is suitable where the relevant debt is intended to be unsecured and unsubordinated, and needs to be in …

What has 2019 meant to us?

Paul Sutton LCN Updates

While we are excited about where our plans for 2020 will take us, our team has also reflected on what we have achieved in 2019, and what 2019 has meant to us. Learning You might think that with over 50 years’ combined experience of managing cross-border projects, we would know all there is to be known about the legal implementation of international …

Jersey / Guernsey / Isle of Man: no agreements, no substance

Paul Sutton Intercompany Agreements

On 22 November 2019, guidance in relation to economic substance requirements was issued jointly by Guernsey, Isle of Man and Jersey. In general, the relevant ‘adequate substance’ requirements mean that (amongst other things) a company must conduct Core Income-Generating Activity (‘CIGA’) in the relevant island, and that activity must be actually …

Substance over form in transfer pricing – a common misconception

Paul Sutton Intercompany Agreements

It is often said that the OECD Transfer Pricing Guidelines emphasize substance over form, when it comes to delineating controlled transactions. This is true insofar as it goes, but it gives rise to a common misconception that functional analysis trumps legal agreements. It’s true that if an intercompany agreement (put in place in advance, or ‘ex …

Free Webinar: How Distributed Ledger Technology can Streamline Intercompany Financing Transactions

Paul Sutton Intercompany Agreements, LCN Updates

Most people have heard of Blockchain, primarily in the context of cryptocurrencies. In fact, Blockchain is just one kind of Distributed Ledger Technology (DLT), which can streamline processes and provide high level information security. For these and other reasons, DLT can be a powerful tool for managing intercompany financial transactions. In this …

FAQs about our Toolkit of Template Intercompany Agreements

Paul Sutton Intercompany Agreements

Sometimes, when you’re very close to the detail of something, you think what you do is obvious, and everyone else should automatically know what you know. But that’s clearly not the case – as shown by the questions we receive about our Toolkit of template intercompany agreements. Here are some of the questions we’ve received in recent months: …

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New for 2020: Document automation tool for creating Loan Note Instruments to document related party debt

What has 2019 meant to us?

Jersey / Guernsey / Isle of Man: no agreements, no substance

Substance over form in transfer pricing – a common misconception

Free Webinar: How Distributed Ledger Technology can Streamline Intercompany Financing Transactions

FAQs about our Toolkit of Template Intercompany Agreements

Email updates