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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.

This is not an axe

Paul Sutton

Sometimes appearances can be deceptive, and the differences between the right tool and the wrong tool may not be immediately apparent. The tool pictured above is not an axe. It’s called a ‘maul’. A maul is thicker, blunter and heavier than a wood-chopping axe. It’s designed for splitting logs along the grain, to make…

Intercompany Agreements

Intercompany Management Fees: Aspro v. Commissioner

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 examines Aspro v. Commissioner. The case recently went before US Court of Appeals, which ruled in favour of the IRS. A…

Intercompany Agreements

An alarming implication of the BlackRock judgment

Paul Sutton

We hope that you found our recent analysis of the BlackRock decision to be thought-provoking and useful. This concluded that while the judgment certainly does have significant implications for groups and their advisers, these are not quite as earth-shattering as they might at first appear. In this blog post we’d like to look at another…

Intercompany Agreements

The LCN Interview: Jim Sams

Paul O’Regan

Jim Sams has been a tax consulting specialist for over 30 years, with around seven years in the public sector followed by 27 years at KPMG. Now semi-retired, he provides training in US international tax to a range of clients. How did you get into tax? I sort of fell into it. I’m…

Interviews

Should default interest terms be included in intercompany agreements?

Paul Sutton

As you may know, every Monday we send out an e-newsletter 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.) Earlier this month I wrote about the choice between bilateral…

Intercompany Agreements

The LCN Interview: Josh Finfrock

Paul O’Regan

Josh Finfrock is a transfer pricing specialist with more than 17 years’ experience of working with multinational businesses. He started his career with a Big Four firm, and has since led transfer pricing for a top-10 national public accounting firm and served as an IRS economist. He is currently Director, Transfer Pricing at Weaver….

Interviews

Intercompany Agreements

HMRC v BlackRock Holdco 5 LLC (19 July 2022 decision): implications for documenting intercompany loans

Paul Sutton

On 19 July 2022, the Upper Tribunal in the UK released a judgment in the case of HMRC v BlackRock Holdco 5 LLC. This overturned the previous decision of the First-tier Tribunal (FTT) and found in favour of HMRC: it disallowed an interest deduction on a $4 billion intercompany loan. How concerned should the TP…

Intercompany Agreements

There are two sides to every story

Paul Sutton

When implementing intercompany agreements for transfer pricing compliance, do you favour multilateral or bilateral ICAs? I’d be interested to hear your view. The legal effect (the rights and obligations between the respective parties) should be the same in both cases. But there’s still a choice to make. To my mind, the big factor in favour…

Intercompany Agreements