Expert Resources

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.

Legal Resources

Briefing on how to create effective Intercompany Agreements for Transfer Pricing

Intercompany Agreements

Issue of Quoted Eurobonds to Related Parties – Preliminary Legal Information Request

Group Reorganisations

Special Report for Legal Counsel – OECD’s Transfer Pricing Guidelines (2017)

Intercompany Agreements

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Paul Sutton

Homer Simpson and me

Paul Sutton Intercompany Agreements
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 …
Paul Sutton

Is this TP clause clever or not?

Paul Sutton Intercompany Agreements
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 …
Paul Sutton

How to be a treasurer

Paul Sutton Personal Blog
This was remark from Coco, our just-turned-7 year old daughter: “I need a box, to treasure things in.” It made me realise that I don’t often use the word “treasure” as a noun, let alone as a verb. So here’s a Monday morning question for you, inspired by Anthony Robbins: What are your most treasured memories in your career so far? And what …
Paul Sutton

Dealing with franchising in TP documentation

Paul Sutton Personal Blog
Intra-group franchising arrangements are not uncommon, and we’ve recently been helping two multinational groups with their intercompany franchise agreements. For one of those clients, we were provided with a benchmarking report produced by one of the ‘Big Four’ firms, which attempted to provide guidance as to an appropriate franchise fee. The …
Paul Sutton

My day with the tax guns

Paul Sutton Personal Blog
Unannounced tax audits may be a fact of corporate life – but you wouldn’t necessarily expect them to involve firearms. This is the subject of an article very kindly contributed by Ian Barron, the former Vice President and Head of Corporate Tax at American Express for the EMEA Region: “I’ve had some interesting and amusing experiences handling …