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Intercompany Agreements

How can a multinational group achieve consistency in its intercompany agreements?

11 October 2016   Paul Sutton

For large corporates, the task of implementing and maintaining robust intercompany agreements can seem daunting. In many cases, a group’s starting point is intercompany documentation reflecting a variety of inconsistent approaches. Here are some of the most common scenarios we come across, often within different parts of the same organisation: No agreements at all Duplication…

Group Reorganisations

Intercompany Agreements

Non-tax drivers for Intercompany Agreements between related parties

31 May 2016   Ivan Hanna

Intercompany agreements are often seen as essential in the context of domestic and international tax and transfer pricing compliance. However, it is also important to remember that there are a number of highly relevant non-tax related drivers for having well drafted intercompany agreements in place between members of a corporate or financial services group. Governance…

Group Reorganisations

Intercompany Agreements

The LCN Transfer Pricing Interview: Stephen Alleway

4 December 2015   Ian Barron

We are delighted to feature an interview with Stephen Alleway who is the Transfer Pricing Partner at Questro International, a specialist TP Consultancy and Director at Otico Software, engaged in developing time-saving tax software. Stephen is a frequent contributor to publications on transfer pricing and speaks widely on the subject in Switzerland and at international…

Interviews

Intercompany Agreements

The LCN Transfer Pricing Interview: Fabio Mastrangelo

5 August 2015   Ian Barron

We are delighted to feature an interview with Fabio Mastrangelo who is the Senior Partner at Studio Mastrangelo, Rome, Italy. Fabio is “Dottore Commercialista” and a highly experienced professional advisor to international groups and multinationals with operations in Italy. He is a tax expert with extensive success in transfer pricing (ruling requests, negotiations with tax…

Interviews

Intercompany Agreements

Should pre-written board minutes be used in group reorganisations?

18 June 2014   Paul Sutton

There can often seem to be a disconnect between the tax world and the legal world. One example of this is attitudes about how decision-making should work in the context of a group reorganisation. And to be more precise: whether it is appropriate to use pre-written board minutes. There is a view – which may…

Group Reorganisations

Intercompany Agreements

The LCN Tax Interview: Justin Walton

8 May 2014   Paul Sutton

We are delighted to feature an interview with Justin Walton, which he kindly gave when he was Head of Tax at John Laing plc. Justin is now the founder of PLS, which provides outsourced tax leadership services to businesses needing regular access to a Head of Tax or Tax Director but without one in their…

Group Reorganisations

Interviews

Intercompany Agreements

The LCN Tax Interview: Brian Sturtz

27 March 2014   Paul Sutton

We are delighted to feature an interview with Brian Sturtz, former Director of International Tax and Transfer Pricing at Walmart Stores, Inc., and former former Director of International Tax at Univar, the global chemicals distribution group. Brian passed away on August 13, 2015. What are your top 3 likes when dealing with national tax administrations? 1) Transparency…

Group Reorganisations

Interviews

Intercompany Agreements

Intercompany agreements for transfer pricing – when is backdating OK?

10 February 2014   Paul Sutton

One of the most common legal questions regarding intercompany agreements is whether an agreement can be backdated. The short answer is no: you cannot give a document a false signature date, as that would almost certainly constitute fraud. What is possible — and often necessary in order to support transfer pricing positions — is to…

Group Reorganisations

Intercompany Agreements
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