What goes around, comes around. Every action has an opposite reaction. Every legal right is matched by a corresponding legal obligation. This is true in the area of international group structures and transfer pricing policies, as it is in every other area of life. For example, a distributor may be intended for TP purposes to be exposed to limited risks …

One of the most common questions we are asked is which law should govern an intercompany agreement (ICA), and to what respect ICAs should be localised. The starting point is that every ICA should specify which law governs it and which courts would have jurisdiction in the case of a dispute. This is because there needs to be a contract in order to achieve …

In the context of transfer pricing, an allocation key is simply a way of apportioning the recharge of centrally incurred cost across multiple beneficiaries. A typical example is head office services such as finance, accounting, tax, legal, HR, IT services etc, where the costs involved do not directly relate to a specific benefitting entity. Typical …

This is a picture of the BMW R32 motorbike, which was the first motorbike to be produced under the BMW brand. You might be surprised to know that it first went into production in 1923, despite not looking out of place decades later. The R32 introduced a number of innovations, including a boxer-twin shaft drive layout which is still in use now. (‘Boxer’ …

In real life, a single clause (or even a single word) in a legal agreement can make a huge difference to the commerciality of an arrangement. Exclusive vs non-exclusive licences. Recourse vs non-recourse factoring. One month vs 12 month subscription terms. Overdrafts repayable at will vs term loans with no right of prepayment. Intercompany transactions …