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Intercompany Agreements

How Intercompany Agreements Shape Transfer Pricing and Customs Compliance

21 February 2026   Paul Sutton

Transfer pricing is rarely the sole driver of intercompany agreements (ICAs) or group legal structures. It is one of several critical factors that must be weighed. ICAs are the factual anchor for a group’s dealings across tax, customs, regulatory, and governance domains, as the recent Tauritus case demonstrates in the context of VAT and customs…

Intercompany Agreements

Why Legal Operating Models Matter More Than Ever

21 February 2026   Paul Sutton

Most multinational groups operate with complex webs of legal entities, cross-border roles, intercompany flows, and regulatory obligations, but very few have a single, coherent framework that explains how all of this is supposed to work. That gap is increasingly becoming a real source of tax, governance and operational risk. Tariff escalation, diverging U.S.–EU approaches to…

Intercompany Agreements

Transfer Pricing and Blocked Income: Lessons from 3M’s Royalty Dispute

24 October 2025   Paul Sutton

In a landmark ruling that reshapes the boundaries of U.S. transfer pricing enforcement, the Eighth Circuit Court of Appeals has sided with 3M in its long-running dispute with the IRS over “blocked income.” The court reversed a $24 million adjustment, holding that U.S. tax law cannot compel recognition of royalty income that a taxpayer is…

Intercompany Agreements

Pricing clauses in intercompany agreements for transfer pricing compliance

24 October 2025   Paul Sutton

A key function of intercompany agreements is to specify the price for the relevant transactions. In general, this requires that the actual amount of the price to be charged is either ascertained or is ascertainable by reference to objective criteria. It is not enough for the parties to agree that the price shall be equal…

Intercompany Agreements

Understanding Commissionaire Arrangements in the context of transfer pricing

18 August 2025   Paul Sutton

Commissionaire structures are a distinctive feature of civil law jurisdictions and frequently appear in the operating models of multinational groups. While the legal concept may seem arcane, its implications for transfer pricing, permanent establishment risks, and intercompany agreement design are far-reaching. At its core, a commissionaire arrangement allows a person or entity to sell goods…

Group Reorganisations

Intercompany Agreements

12 Lessons in Intercompany Transaction Design, from 12 Years of LCN

8 August 2025   Paul Sutton

This summer marks our 12th anniversary at LCN. If you work in transfer pricing or handle cross-border intra-group transactions, you’re the community we’re here to support, and we’re honoured to be on this journey with you Here’s a summary of 12 key lessons we’ve learned in our journey TP is just one of many stakeholders…

Intercompany Agreements

9 Key Questions for Intercompany Loan Agreements

5 August 2025   Paul Sutton

How to scope out intercompany agreements that deal with loans and indebtedness Intercompany debt remains one of the more complex and scrutinised areas of transfer pricing compliance – especially when it comes to loans and financial arrangements between associated enterprises within multinational groups. This article outlines nine essential areas to assess before preparing or reviewing…

Intercompany Agreements

Inventec’s Czech Contract Manufacturing Litigation: Benchmarking Issues from an economic perspective

25 July 2025   Guest Author

This is a guest post by Harold McClure, a New York City-based independent economist with 26 years of transfer pricing and valuation experience. Several weeks ago, an LCN newsletter looked at the case of Inventec (Czech), s.r.o. a subsidiary of the Taiwanese based multinational Inventec Corporation. We thought it would be instructive to take a…

Intercompany Agreements
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