Group Reorganisations

How we healthcheck intercompany agreements for TP compliance

When we’re reviewing intercompany agreements, we look at four key areas of alignment with TP policies: the delineation of the transaction, the risk allocation, the treatment of IP and intangibles, and the pricing. We also look at a fifth area, namely general fitness for purposes. This includes obvious things such as whether the parties…

Group Reorganisations

LCN Updates

Intercompany Agreements

Top 10 ‘hidden assets’ which can be missed in Global Value Chain restructuring or legal entity reduction projects

Paul Sutton

Corporate groups tend to acquire more and more legal entities over time – whether as a result of M&A activity, SPVs created for specific projects or (in some cases) tax planning. Most groups therefore need to clear out unnecessary entities from time to time. Some larger groups have in excess of 1,000 legal entities, and…

Group Reorganisations

LCN Updates

Intercompany Agreements

Free Webinar on how to you can easily introduce document automation

Paul Sutton

I’m really passionate about the potential of document automation. At LCN, we use it for relatively straightforward things like engagement letters and proposals, and for more complex suites of documents such as inserting a new holding company into a group. We also apply automation to external-facing workflows, such as our free tool for scoping out…

Group Reorganisations

LCN Updates

Intercompany Agreements

Cash pooling – a legal perspective

Paul Sutton

Thanks very much to everyone who attended our recent interactive webinar on the basics of intercompany agreements for financial transactions. If you missed it, you’ll find a recording here. One of the issues we discussed was cash pooling arrangements, both physical and notional, and in this blog post I’d like to delve a little deeper into…

Group Reorganisations

Intercompany Agreements

Join us at TP Minds Americas on 18th and 20th April

Paul O’Regan

This year we are again sponsoring the TP Minds America conference. We’ll be taking part in three events. On 18th April, Paul Sutton will participate in a workshop hosted by BDO on the co-ordination of transfer pricing with customs and trade considerations. On 20th April, Leiza Bladd-Symms will take part in a panel that will examine…

Group Reorganisations

LCN Updates

Intercompany Agreements

Your thoughts on ‘putting the cart before the horse’

Paul Sutton

We recently wrote a blog post about the factors that should dictate a group’s contracting model (‘Putting the cart before the horse?’). It was inspired by the following extract from a TP report by a Big Four firm (my italics): “The Group utilises a centre-led operating model, whereby client contracts are entered into by either…

Group Reorganisations

Intercompany Agreements

Live Workshop on 17 February: Intercompany Agreements for Transfer Pricing Compliance 101

Paul O’Regan

Few subjects in TP seem to be as misunderstood as intercompany agreements and group contracting models. This can lead to TP policies which make no sense. I came across a good example last week, in a TP report produced by the Los Angeles office of a Big Four firm. The report benchmarked manufacturing support services…

Group Reorganisations

Interviews

What we can learn from Singtel: webinar discussion with Johann Müller

Paul O’Regan

Following on from two recent blog posts by Paul Sutton and Harold McClure that related to the recent tax case involving Singapore Telecom Australia, we have completed the trilogy in a webinar with Johann Müller. Johann is a very experienced expert in international tax. In this discussion he looks at the details of the structure that…

Group Reorganisations

Interviews