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Intercompany Agreements

Checklists for creating, reviewing & updating Intercompany Agreements

24 May 2021   Paul Sutton

Defective intercompany agreements can undermine your transfer pricing policies, and can give rise to unnecessary risks of adverse tax adjustments, fines and penalties. The team at LCN Legal have created a suite of practical checklists which is designed to help multinational groups ensure that their intercompany agreements are aligned with their transfer pricing policies, and…

Intercompany Agreements

Transfer Pricing Override Clauses – Yes or No?

26 April 2021   Paul Sutton

We are sometimes asked to include ‘Transfer pricing override’ clauses in intercompany agreements (ICAs). These clauses are intended to adjust the contractual price to the price charged for tax purposes if there is a TP adjustment at either end of the transaction. This sounds like a good idea: a clause which can go back in…

Intercompany Agreements

Coca-Cola: Contractual terms vs economic substance

12 January 2021   Paul Sutton

In transfer pricing analysis, which prevails: the contractual terms of a related party transaction, or the economic substance? The general view expressed by many TP professionals is that economic analysis is king. The Court’s decision in the recent Coca-Cola case shows that this view is at best simplistic – and for practical purposes as a…

Intercompany Agreements

Video Interview: Update on HMRC’s Profit Diversion Compliance Facility

22 October 2020   Paul Sutton

Many thanks to Ken Almand for sharing his insights and updates on HMRC’s Profit Diversion Compliance Facility (PDCF), including his commentary on HMRC’s webinar last week. Questions we discussed included: * Did HMRC’s webinar on 6th October tell us anything new? * What have we learned from our experiences with the PDCF so far? In which situations…

Interviews

Intercompany Agreements

China Handbags Case Study 14.2 and the Abuse of the Deductive Value Method

17 September 2020   Paul Sutton

The following article is part of a series of case studies and articles which have been kindly contributed by Dr Harold McClure, a New-York based economist who has advised in the area of transfer pricing for many years. In our previous discussion of customs valuations in China, we presented a hypothetical example to capture the…

Intercompany Agreements

Do you have a protocol for handling TP audits?

7 September 2020   Paul Sutton

One of the things I love about attending conferences like TP Minds International last week, is that (as an adviser) you get insights into the real-life practicalities of managing TP risks, as opposed to just high level theory and crystal ball-gazing. One of the polling questions we asked on the panel session I hosted on…

Intercompany Agreements

Checklist for intercompany agreements for the distribution or resale of goods

27 July 2020   Paul Sutton

Sometimes, you just want to have the information with no fluff or fuss. We’ve created a three-page checklist for creating, reviewing or updating intercompany agreements for the distribution or resale of goods. You can download it here. You might be wondering why we share this kind of information for free. It’s because one of our…

Intercompany Agreements

Quick-start workshops for revising your group’s Transfer Pricing agreements

21 July 2020   Paul Sutton

I’ve lost count of the number of transfer pricing articles I’ve read over the last couple of months which tell their readers to “review your transfer pricing policies” and “update your intercompany agreements” in the light of recent economic circumstances. This is undoubtedly good advice. The problem is that few TP or tax professionals know…

Intercompany Agreements
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