Intercompany Agreements

How to Put in Place Effective Intercompany Agreements for Transfer Pricing Compliance

SPEED READ The fundamental requirement of intercompany agreements (ICAs) for multinational enterprises is clearly that they are consistent with the transfer pricing analysis. This now includes ensuring that contractual allocations of risk, capital, and IP ownership are supportable under DEMPE-based substance tests, which tax authorities increasingly scrutinise in the post-BEPS and Pillar Two environment. They…