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.
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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.