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Intercompany Agreements

The LCN Interview: Josh Finfrock

11 August 2022   Paul O’Regan

Josh Finfrock is a transfer pricing specialist with more than 17 years’ experience of working with multinational businesses. He started his career with a Big Four firm, and has since led transfer pricing for a top-10 national public accounting firm and served as an IRS economist. He is currently Director, Transfer Pricing at Weaver. How…

Interviews

Intercompany Agreements

HMRC v BlackRock Holdco 5 LLC (19 July 2022 decision): implications for documenting intercompany loans

3 August 2022   Paul Sutton

On 19 July 2022, the Upper Tribunal in the UK released a judgment in the case of HMRC v BlackRock Holdco 5 LLC. This overturned the previous decision of the First-tier Tribunal (FTT) and found in favour of HMRC: it disallowed an interest deduction on a $4 billion intercompany loan. How concerned should the TP…

Intercompany Agreements

Working out what intercompany agreements are required doesn’t have to be hard work

18 July 2022   Paul Sutton

You’ve established that a group’s suite of ICAs isn’t fit for purpose. Good. Next question: what exactly is likely to be required? That’s a bit more difficult to answer. We think that our free scoping tool will be a great help. We designed it together with our long-term supplier Documate, who are experts in automating…

Intercompany Agreements

Happy Independence Day!

4 July 2022   Paul Sutton

A very happy Independence Day to all of our readers with a USA connection. To mark the occasion, we’d like to share something that may help you to comply with the US Treasury rules concerning Cost Sharing Arrangements (CSAs), also known as Cost Contribution Arrangements (CCAs). These rules are unusual in the world of intercompany…

Intercompany Agreements

Documenting ‘target margin’ arrangements: you have two choices

1 July 2022   Paul Sutton

When you’re dealing with a controlled transaction which is priced on a ‘target margin’ basis (e.g. so-called limited risk distribution), you have two main options as regards the pricing clause in your intercompany agreement. Option 1 can be described as a ‘framework agreement’. In this approach, the agreement does not actually specify the price payable by the…

Intercompany Agreements

The LCN Interview: Andrew Spiers

21 June 2022   Paul O’Regan

Andrew Spiers is a Senior Associate at LCN Legal. He has extensive experience of a wide range of corporate legal work. As we speak you’ve been at LCN Legal for about a month; has the reality matched your expectations? To be honest, it has exceeded them. Everyone has been fantastic, and the work is really…

Interviews

Intercompany Agreements

Sweden prevails in intercompany loan arrangements where the taxpayer attempted to ignore its original agreements

9 June 2022   Guest Author

This is a guest post by Harold McClure, a New York City-based independent economist with 26 years of transfer pricing and valuation experience. Here he examines the recent judgment in the case Sweden vs. Nobel Biocare Holding AB, and highlights its main implications.    Sweden vs. Nobel Biocare Holding AB (HFD 2016 ref. 45) involved a…

Intercompany Agreements

Aspro, Inc. v. Commissioner: déjà vu all over again

5 June 2022   Paul Sutton

I follow many TP and tax experts on LinkedIn, and one that I’d recommend is Filippo Miotto of BDO Australia. He recently shared an article that I found particularly striking. It concerned a recent judgment in a tax case in the USA, Aspro, Inc. v. Commissioner, which concerned the years 2012 to 2014. Over an extended period, Aspro had paid its…

Intercompany Agreements
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