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Intercompany Agreements

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

7 October 2019   Paul Sutton

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…

Intercompany Agreements

Should Intercompany Agreements be put in place between a ‘parent’ company and its own permanent establishment / branch?

29 October 2018   Paul Sutton

This question came up again last week on a transfer pricing project (many thanks to AH and NA for raising it!). The issue was how the relationship between ‘parent’ company and its own branch / permanent establishment (PE) should be documented – and specifically the use of a memorandum vs a document in the style…

Intercompany Agreements

Q&A on Chapter VII OECD TP Guidelines and Intercompany Agreements

24 October 2018   Paul Sutton

One of the most rewarding things about running seminars and webinars is questions from participants, and the different perspectives which they bring. In case you’re interested, I’ve set out below one of the questions which was raised at our webinar on Tuesday (thank you Daniel!), together with our response. Q: Would you please provide some…

Intercompany Agreements

Revised and updated: Free resource to help you assess your intercompany agreements for TP compliance

5 October 2018   Paul Sutton

Just a quick one: we’ve just revised and updated one of our free resources: it’s a self-assessment questionnaire, to help you ascertain how well your group’s TP policies are supported by intercompany agreements, and prioritise which types of transaction you need to address first. You can download it here. N.B. If you’re a light on CPD…

Intercompany Agreements

For Technology-rich Groups: invitation to Free Webinar on Intercompany Agreements for TP Compliance

25 September 2018   Paul Sutton

This may be of interest to you if you’re supporting a multinational group in the technology sector on its Transfer Pricing compliance: On Thursday 11 October at 0900 Pacific Daylight Time / 1700 UK Time, we’ll be hosting a free webinar on How to Create Effective Intercompany Agreements for Technology-Rich Multinational Groups. You will be…

Intercompany Agreements

What are the differences between intercompany agreements and ‘normal’ agreements?

15 March 2018   Paul Sutton

This question came up on Tuesday, with the lovely people at Thomson Reuters ONESOURCE Transfer Pricing in Canary Wharf. Here’s a brief run-down of the main differences: Intercompany agreements (also known as ‘ICAs’) are usually much shorter. For example, a typical distribution agreement between unconnected parties would often be 40 to 50 pages in length,…

Intercompany Agreements

Intercompany agreement review service for multinational groups.

26 February 2018   Paul Sutton

This article appears in the February edition of our International Corporate Structures Newsletter. We help you to spot and correct issues in your existing documentation (including identifying gaps) before they become a problem for you, by reviewing your existing template agreements, and giving you feedback as to how they can be improved. Our healthcheck review…

Intercompany Agreements

Is your group structure ready for the tax inspectors? I mean, really ready?

26 February 2018   Paul Sutton

This article appears in the February edition of our International Corporate Structures Newsletter. If you are a regular reader of this newsletter, and of our regular emails, publications, legal resources and guides, you will know that we are advocates of effective intercompany agreements and related structures for multinational groups. Of course we are; a group…

Group Reorganisations

Intercompany Agreements
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