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Intercompany Agreements

Intercompany Invoice Finance: four key legal distinctions

11 May 2022   Paul Sutton

Factoring and invoice discounting can be used as part of intercompany financing arrangements. The terminology involved can differ from country to country, so before attempting a transfer pricing analysis it’s critical to look behind that terminology, and understand what is actually happening from a legal and commercial perspective. Here are four fundamental legal distinctions: 1….

Intercompany Agreements

Start with the end in mind

2 May 2022   Paul Sutton

I’ve decided to set myself a mini-challenge: to post something on LinkedIn every working day. I’ll try it out for a month, and then decide whether sharing insights has given way to verbal diarrhoea. It has been interesting so far, as it requires me to reflect on points regarding the legal implementation of TP that…

Intercompany Agreements

Live Workshop on 28 April: Intercompany Agreements for Limited Risk Arrangements

11 April 2022   Paul O’Regan

Thanks very much to everyone who participated in our interactive workshop on financial transactions. You’ll find a recording of one of the sessions here. Our next workshop is on Thursday 28 April. It will focus on the legal implementation of limited risk arrangements in transfer pricing, including: What are limited risk arrangements? What is required for…

Intercompany Agreements

Cash pooling – a legal perspective

28 March 2022   Paul Sutton

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…

Intercompany Agreements

Group Reorganisations

The LCN Interview: Borys Ulanenko

21 February 2022   Paul O’Regan

  Borys Ulanenko is a transfer pricing professional, currently working in Krakow as part of Royal Dutch Shell’s in-house team. He also runs StarTax Education, a company he created that provides high-quality and affordable educational materials for people who are studying TP. How did you get into transfer pricing in the first place? It was mainly…

Interviews

Intercompany Agreements

What would you like to see in our updated book on intercompany agreements?

24 January 2022   Paul O’Regan

We’ve decided to create a new version of our book: ‘Intercompany Agreements For Transfer Pricing: A Practical Guide’. It was first published in March 2019, and we’d like to reflect changes in transfer pricing governance and in the commercial environment since then. We also want it to much more closely reflect the content of our…

Intercompany Agreements

Board resolutions: the costs of complexity

17 January 2022   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…

Intercompany Agreements

Group Reorganisations

End of LIBOR, and the Singapore Telecom Australia decision

10 January 2022   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…

Intercompany Agreements

Group Reorganisations
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