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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.

What would you like to see in our updated book on intercompany agreements?

24 January 2022   Paul O’Regan

We’ve decided to create a new version of our book: ‘Intercompany Agreements For Transfer Pricing: A Practical Guide’. It was first published in March 2019, and we’d like to reflect changes in transfer pricing governance and in the commercial environment since then. We also want it to much more closely reflect the content of our…

Intercompany Agreements

Board resolutions: the costs of complexity

17 January 2022   Paul Sutton

In our last blog I examined the recent judgment in Australia in which the ATO succeeded in litigation with Singapore Telecom Australia. One of several striking features of that case was that the group had seemingly set up a financing arrangement that the directors of the entities concerned could not have properly approved. It also…

Intercompany Agreements

Group Reorganisations

End of LIBOR, and the Singapore Telecom Australia decision

10 January 2022   Paul Sutton

As of 1 January this year, 24 of the 35 LIBOR interest rate benchmarks or ‘settings’ are no longer published. What does this mean for groups which still have intercompany loan agreements, loan notes or cash pooling arrangements that refer to LIBOR? On the face of it, it’s very simple: select an alternative risk-free rate…

Intercompany Agreements

Group Reorganisations

The LCN Interview: Philippe Paumier

18 November 2021   Paul O’Regan

Philippe Paumier is a transfer pricing expert with over 20 years’ experience, most of it acquired as an in-house expert in major multinationals. In 2019 he founded VECTOR TP, which combines in-house know-how on transfer pricing with extensive international practical experience. Tell us more about VECTOR TP: what makes it different? I started with a…

Interviews

Intercompany Agreements

The LCN Interview: Rebecca Flanagan

27 October 2021   Paul O’Regan

Rebecca has just joined the LCN Legal team as a Director. She brings a lot of experience of advising on M&A and group reorganisations.   How did you become a specialist in group reorganisations? I did my training contract at Clifford Chance, and I worked there for about four years post-qualification. Then I moved to…

Interviews

Group Reorganisations

Intercompany Agreements

The LCN Interview: Adrian Camara

21 September 2021   Paul O’Regan

Adrian Camara is co-founder and CEO of Athennian. The company provides a cloud-based legal entity management system, used by law firms and in-house teams to manage complex corporate groups. Launched in 2017, the business has grown rapidly and now has 89 employees across its HQ in Calgary, Canada, and other offices in North and South…

Interviews

The Pfizer Panama decision: A compelling case for an ICA healthcheck?

13 September 2021   Paul O’Regan

I’d like to draw your attention to a Resolution of the Administrative Tax Court of Panama of 9 July 2021, which set a precedent for transfer pricing in Panama. Many thanks to Miguel Medeiros at Sol Petroleum for highlighting the case and for sharing his thoughts on it. As always, we’re extremely grateful for the feedback we…

Intercompany Agreements

Transfer Pricing Risks in Intercompany Transactions: How Invoicing Frequency Affects Compliance and Tax Exposure

1 September 2021   Paul Sutton

We recently spoke to tax professionals to gauge how invoicing frequency—particularly annual invoicing—affects compliance risk. The responses were overwhelming and often surprising, which we explore in detail below. Perspectives on Invoicing Frequency in Transfer Pricing While some practitioners hadn’t viewed invoicing frequency as a material risk, others highlighted its impact—especially in high-interest jurisdictions. Elevated statutory…

Intercompany Agreements
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