This free tool consists of an online questionnaire which collects the relevant information regarding the ‘main benefit’ test and the applicable ‘hallmarks’, and applies the logic regarding the inter-relationship of the hallmarks and the main benefit test as prescribed by the DAC. The output is a Word document which contains a log of the responses made, as well as an executive summary of conclusions on reportability in the form of a ‘traffic light’ report.
The tool is made available for free on an ‘as is’ basis. Any use of the tool is at the user’s sole risk. No responsibility or liability is accepted on the part of LCN Legal or any other parties who have contributed to the development or hosting of this tool.
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About LCN Legal
LCN Legal is described by the UK’s Chartered Institute of Tax as “a world leader in creating legal substance for Transfer Pricing compliance,” and the firm’s co-founder Paul Sutton is the author of the seminal book ‘Intercompany Agreements for Transfer Pricing Compliance – A Practical Guide,’ published by Law Brief Publishing.
In addition to providing hands-on legal support on legal structures for multinational groups, the firm also provides various tools and resources including its 10-module Online Course on Intercompany Agreements and its Toolkit of Template Intercompany Agreements for Transfer Pricing compliance.