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Intercompany Agreements

The LCN Interview: Philippe Paumier

18 November 2021   Paul O’Regan

Philippe Paumier is a transfer pricing expert with over 20 years’ experience, most of it acquired as an in-house expert in major multinationals. In 2019 he founded VECTOR TP, which combines in-house know-how on transfer pricing with extensive international practical experience. Tell us more about VECTOR TP: what makes it different? I started with a…

Interviews

Intercompany Agreements

The LCN Interview: Rebecca Flanagan

27 October 2021   Paul O’Regan

Rebecca has just joined the LCN Legal team as a Director. She brings a lot of experience of advising on M&A and group reorganisations.   How did you become a specialist in group reorganisations? I did my training contract at Clifford Chance, and I worked there for about four years post-qualification. Then I moved to…

Interviews

Group Reorganisations

Intercompany Agreements

The Pfizer Panama decision: A compelling case for an ICA healthcheck?

13 September 2021   Paul O’Regan

I’d like to draw your attention to a Resolution of the Administrative Tax Court of Panama of 9 July 2021, which set a precedent for transfer pricing in Panama. Many thanks to Miguel Medeiros at Sol Petroleum for highlighting the case and for sharing his thoughts on it. As always, we’re extremely grateful for the feedback we…

Intercompany Agreements

Transfer Pricing Risks in Intercompany Transactions: How Invoicing Frequency Affects Compliance and Tax Exposure

1 September 2021   Paul Sutton

We recently spoke to tax professionals to gauge how invoicing frequency—particularly annual invoicing—affects compliance risk. The responses were overwhelming and often surprising, which we explore in detail below. Perspectives on Invoicing Frequency in Transfer Pricing While some practitioners hadn’t viewed invoicing frequency as a material risk, others highlighted its impact—especially in high-interest jurisdictions. Elevated statutory…

Intercompany Agreements

Does frequency of invoicing matter in intercompany transactions?

23 August 2021   Paul Sutton

This week we’d like to ask you for your insights. When we work alongside TP professionals to create intercompany agreements for multinational groups, we typically focus on the four main areas of alignment: 1. Delineating the transaction through the parties’ functions and obligations 2. Allocation of risk 3. Ownership of intangible assets 4. Pricing, including…

Intercompany Agreements

Making comparability transparent

2 August 2021   Paul Sutton

One of the key functions of intercompany agreements is to be transparent as regards key matters such as risk allocation, compensation (pricing), and ownership of intangible assets. What does ‘transparent’ mean in this context, and why does it matter? Transparency requires that intercompany agreements should be easily understood by the reader, no matter who that…

Intercompany Agreements

Coca-Cola’s US$ 12 billion IP mistake

24 June 2021   Paul Sutton

The following article first appeared in IP Briefs, the journal of the South African Institute of Intellectual Property Law. One might think that an organisation with one of the most recognised and valuable brands in the world, founded in 1892, might be a well-oiled machine when it comes to managing its intellectual property rights. And…

Intercompany Agreements

How should TNMM / CPM arrangements be implemented in ICAs?

8 June 2021   Paul Sutton

Some TP methods – specifically, the cost plus method – imply a specific drafting structure for pricing clauses in intercompany agreements (ICAs). Others do not. Take for example, the Transactional Net Margin Method (TNMM), aka the Comparable Profits Method (CPM). This method may suggest a drafting approach based on the relevant profit or margin, or…

Intercompany Agreements
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