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.

Paul Sutton

Swimming pools and allocation keys

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 …
Paul Sutton

What if BMW designed transfer pricing documentation?

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’ …
Paul Sutton

Can a single clause in an intercompany agreement make a 20% difference to the pricing of a controlled transaction?

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 …
Paul Sutton

PRESS RELEASE: LCN Legal announces first ever online platform for the creation of bilingual intercompany agreements for transfer pricing

LCN Legal is delighted to announce the launch of its new ‘Fast Track’ service for the creation of intercompany agreements for Transfer Pricing compliance. Benefitting from LCN Legal’s world-leading expertise in Intercompany Agreements and feedback from a global community of leading transfer pricing professionals, the new Fast Track service is …