Group Reorganisations

Cash pooling – a legal perspective

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

Board resolutions: the costs of complexity

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…

Group Reorganisations

Intercompany Agreements

End of LIBOR, and the Singapore Telecom Australia decision

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…

Group Reorganisations

Intercompany Agreements

The arm’s length principle: fact or fiction?

Paul O’Regan

We hope you enjoyed our recent interview with Philippe Paumier. We found it very thought-provoking, and in fact we’d like to share some of those thoughts with you here. The starting point is Philippe’s statement: “TP is a construction. It’s a theoretical construction. The very basic and fundamental point of transfer pricing is that parties have to behave…

Group Reorganisations

Intercompany Agreements