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Drafting of Intercompany Agreements for Transfer Pricing Compliance

Dedicated Legal Support for TP Professionals

Transfer Pricing policies and documentation are unlikely to withstand tax audit unless they are legally implemented by intercompany agreements which are aligned with the intended allocation of functions and risks.

  • Arrange a free consultation within minutes
  • World-leading legal experts in Intercompany Agreements
  • Discussion draft Intercompany Agreements typically produced within 10 days of instruction
  • Trusted by MNEs with aggregate revenues of over US$ 130 billion p.a.
  • Trusted by leading Transfer Pricing professionals globally

Because risk allocation cannot be backdated, time is of the essence. The longer that gaps or misalignments in intercompany agreements are left unfixed, the bigger the amount of tax at stake including adverse TP adjustments, double taxation, fines and penalties.

LCN Legal are leading experts in intercompany agreements globally. We provide fast, efficient support for Transfer Pricing professionals. We don’t provide tax or transfer pricing advice, so we don’t compete with the services which they provide.

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Schedule a FREE consultation with one of our specialists. Usually within 48-Hours.

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How we work alongside Transfer Pricing professionals


We provide a free, no-obligation consultation to discuss the transaction types involved. Schedule a time in your diary now.


We are generally able to provide a fixed fee quote within 48 hours for preparation of tailored Intercompany Agreements, which you can pass on to your client.


Once the fee quote has been approved in principle, we issue an engagement letter to the client which incorporates that quote.


We then review the relevant Transfer Pricing information and group structure chart to confirm the transaction types involved from a legal perspective. If necessary, we have a conversation with you to confirm the nature of the relevant transactions.


We produce a discussion draft of each Intercompany Agreement type, usually within 10 days of being instructed. Typical examples include central support services, strategic services. R&D services, marketing services, appointment of limited risk or full risk distributors or resellers, commissionaire agreements, IP licences, cost sharing agreements / cost contribution agreements, loan agreements or loan notes and cash pooling agreements.


We finalise the agreements following input from you and your client, and we prepare a briefing note for directors of the relevant entities.


We provide legal assistance with the implementation of the Intercompany Agreements as needed. This may include localisation of the agreements and preparation of translations.


We check in with the client at regular intervals afterwards, to identify any changes which may require the Intercompany Agreements to be updated.

Free Guide: Effective Intercompany Agreements for TP Compliance