Outsourced global management of intercompany agreements and corporate structures

Global Maintenance Service

LCN’s Global Maintenance Service gives multinational groups flexible ongoing support, to ensure that intercompany agreements and corporate legal structures are managed and maintained worldwide.

We complement and enhance in-house legal teams, who may not have a background in the requirements of the OECD Transfer Pricing Guidelines and operational transfer pricing processes. We apply a systematic approach to managing ongoing audit-readiness and transaction-readiness of intercompany agreements and cross-border corporate structures.

Multinational corporations – ranging from scale-ups to Fortune 500 groups – rely on us to ensure compliance and efficiency with the personalized support of a dedicated expert backed by the LCN team and our market-leading know-how.

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Winner, LexisNexis Legal Awards 2023 - International Team of the Year

Trusted by Multinational Groups with Combined Annual Revenues of Over USD 160 Billion

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Maximize Value and Minimize Risks with LCN

Maintaining tax-audit-ready and transaction-ready agreements is essential for managing tax risks for international groups. Solid legal foundations and streamlined transaction flows enhance shareholder value and reduce compliance costs.

Mitigate Transfer Pricing and Tax Risks

Reduce risks arising from lack of legal substance in intercompany transactions and failure to implement transfer pricing policies legally.
  • Avoid unnecessary double taxation, fines, penalties and transfer pricing adjustments
  • Avoid unnecessary disallowance of corporation tax deductions
  • Avoid costs of unnecessarily protracted audits and enquiries
  • Peace of mind that your group is protected legally

Optimize Shareholder Value

Transaction-ready and fit-for-purpose corporate structures with clear ownership of intangible assets.
  • Transaction-ready
  • Due diligence-ready
  • Enhance enforceability of intellectual property rights
  • Improve overall financial transparency

Reduce Compliance and Transaction Costs

Eliminate unnecessary complexity and wasted management time caused by misalignment between tax compliance policies and legal structures.
  • Streamlined and orderly transaction flows
  • Dividend blocks removed
  • Clearly documented rationale for intra-group transactions

Minimize Personal Liability Risks

Protect legal entity directors by documenting the commercial rationale for intercompany transactions, and demonstrating that directors have complied with their fiduciary and regulatory duties.
  • Reduce risks of personal liability claims against legal entity directors
  • Manage solvency and regulatory risks affecting individual legal entities
  • Demonstrate appropriate legal entity governance

Outsourced legal support to maintain audit-readiness and transaction-readiness

Our Global Maintenance Service ensures intercompany agreements and are compliant and effective worldwide. We support multinational corporations and their advisers with continuous compliance and operational stability.

For tax teams

Maintain Global Compliance

The burden of maintaining intercompany agreements and group structures often falls on members of the tax or finance function. Your in-house legal team may be willing to help, but may lack specialist knowledge in the requirements of the OECD Transfer Pricing Guidelines and the legal aspects of operational transfer pricing, and may not be able to provide pro-active guidance on international best practice.

LCN fills this gap by providing ongoing legal support to tax and finance teams which is flexible and dedicated to the corporate structure needs of multinational groups.

  • Dedicated LCN point of contact, providing continuity and accountability
  • Full support of LCN’s team, specialist know-how and global network
  • Transparent monthly budgets
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For legal teams

Specialist Outsourced Support

We support in-house legal teams, by providing ongoing guidance and flexible support in the highly specialist area of intercompany agreements, transfer pricing compliance and cross-border corporate structures.
  • Pro-active support, to complement and enhance your existing know-how
  • Systematic approach, to help identify and fix blind spots
  • Flexible and collaborative management of tasks and issues, utilizing capacity in your team where applicable
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Our Approach to Supporting Your Business Growth

At LCN, we develop legal strategies that align with your business goals. We provide tailored services in key legal areas for global companies. We aim to help your business succeed.

Consultation

Discuss your needs and connect you with a dedicated LCN specialist who will be your main contact person.

Goals

We focus on seven key legal areas that are important for multinational companies involved in tax audits and transactions.

Support

We offer ongoing support based on priorities, utilizing LCN’s global expertise within a fixed monthly budget.

The 7 Legal Foundations of Effective Corporate Structures

As part of our onboarding of multinational groups, we review the 7 key legal areas which are the foundations of an effective and audit-ready group structure. These 7 legal foundations also provide a focus for ongoing review as part of our maintenance service.

1. Entities, officers, group structure and governance

This includes:
  • entity registrations
  • entity-by-entity decision-making
  • fiduciary duties and conflicts of interest
  • dividend flows / dividend blocks
  • maintenance of capital
  • solvency risks
  • UBO / PSC reporting
  • listed securities and reporting obligations to exchanges
  • ESG policies
  • ongoing programs for consolidation of entities / removal of dormant entities

2. External transaction flows, operating model and compliance model

This includes:
  • contracting model with customers, suppliers and distributors
  • location and ownership of fixed assets
  • chain of title to raw materials and finished goods, where applicable
  • chain of possession of raw materials and finished goods, where applicable
  • procurement approvals
  • obligations of regulated entities
  • data protection compliance and binding corporate rules
  • risks of third party claims and litigation (including product liability, health & safety etc)
  • ringfencing of risk
  • insurance policies, and which entities are loss payees

3. IP ownership, protection and enforcement

This includes:
  • registered IP
  • unregistered IP
  • confidential information
  • know-how
  • litigation strategy

4. Staff contracting model

This includes:
  • contracting models for employees, contractors
  • secondments
  • alignment of incentive structures and KPIs with transfer pricing policies

5. JVs, minority shareholdings and equity incentives

This includes:
  • joint ventures with third parties
  • minority shareholdings held by third parties
  • equity interests held by managers and staff

6. Intercompany transaction flows and agreements

This includes:
  • legal design and implementation of transfer pricing policies
  • contractual allocation of risk and reward
  • services flows
  • chain of title to intellectual property rights
  • chain of title to raw materials and finished goods, where applicable
  • chain of possession of raw materials and finished goods, where applicable
  • characterisation of transactions for the purposes of WHT and VAT
  • legal support for post-year-end adjustments

7. Intercompany debt and equity

This includes:
  • capital / equity structure of subsidiaries
  • regulatory capital, where applicable
  • intercompany loans
  • intercompany balances
  • cash pooling
  • guarantees
  • security given for third party loan facilities
  • parent company support
  • characterisation of financial transactions for tax purposes

Ensure Global Compliance Today

Take action now to put your intercompany agreements and corporate structures in safe hands, so that they are compliant and effective across all jurisdictions.
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Why Choose LCN?

Expert Management of Intercompany Agreements and Legal Structures

Assurance and Peace of Mind

Our expertise in international best practices ensures compliance and reduces tax risks.

Avoid Delays and Wasted Time

We save you significant time by giving you clear direction and hands-on support in the highly specialist area of legal implementation of transfer pricing compliance.

Minimize Ongoing Costs

We streamline intercompany agreements and corporate structures, reducing complexity, risk and transaction costs.

The LCN Difference

  • World-Leading Experts
We are recognized educators in the legal implementation of transfer pricing policies.
  • Global and Cross-Functional Approach
We consider the needs of wider stakeholders – not just transfer pricing – to minimize risks and optimize value for the group concerned.
  • Ongoing Audit-Readiness Support
We maintain agreements in a tax-audit-ready central archive so that they can be produced quickly when required to respond to tax enquiries and due diligence information requests.
  • Diverse Client Base
We work with Fortune 500 companies and scale-ups.
  • Collaborative Approach
We work collaboratively with tax and transfer pricing professionals to help provide clients with better outcomes.
  • Proven Track Record
We are trusted by leading tax and transfer pricing advisers and by corporates with combined annual revenues of over US$160 billion.

Schedule Your Consultation

Book a consultation with our experts to discuss how we can help you maintain and optimize your intercompany agreements globally.

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