Here’s an experiment you can do if you’re a parent, after a weekend with your children: remember how many things they have done which triggered inappropriately intense emotions in you. Here are some of the things on my list: Leaving the tops off felt tip pens Colouring themselves with felt tip pens Colouring walls with felt tip pens Having an unwiped, …

For most multinational businesses, there are 4 or 5 types of intercompany transaction which are key to delineating the relationship between group companies, from a governance and transfer pricing perspective. Each of those types of transaction needs a ‘master template’ intercompany agreement (ICA), to map out the allocation of risk and reward, rights …

Just a quick one: we’ve just revised and updated one of our free resources: it’s a self-assessment questionnaire, to help you ascertain how well your group’s TP policies are supported by intercompany agreements, and prioritise which types of transaction you need to address first. You can download it here. N.B. If you’re a light on CPD for the …

It’s been a tense few days here at Chateau Sutton. You might have already gathered that I’m not known for my home improvement skills. Winter is clearly just around the corner, and the radiator thermostat in the ‘toy room’ on the top floor has been broken since last winter. My boss Xiaofang was not happy about that. I decided to take a chance …

Self delusion is an important skill, and one which I share with Homer Simpson in many aspects of my life. Sometimes this requires intense effort, such as at passport renewal time – when it’s increasingly hard to deny the fact that I’m not as quite youthful-looking as my photo from 10 years ago. Some large corporates seem to be equally adept at …

Earlier this week, one of our friends shared with us an unusual clause in an intercompany agreement (ICA). (Thank you Dawn!) Here it is – I would be interested to hear what you think of it: “If any provision of this Agreement is challenged by [name of tax authority] or any other tax authority in any other jurisdiction on the basis that it is not …