Most large corporates regard transfer pricing as one of the most significant areas of tax risk. Intercompany agreements have long been recognised as an essential part of transfer pricing risk management. Although this aspect is often “owned” by the tax functions of large corporates, the members of those teams are often unaware of the wider implications of intercompany agreements, including enforcement and defence of intellectual property, ring-fencing liability risks, limiting directors’ exposure to personal liabilities, and corporate governance.
In-house legal teams therefore have a critical role to play in providing or procuring appropriate support.
LCN Legal has launched a series of free seminars to educate in-house legal counsel on transfer pricing, the role of intercompany agreements, and how to implement and maintain them.
Who this training is for
These free training sessions are exclusively for legal counsel in large multinational corporates. For details of our training sessions for in-house tax, transfer pricing and finance teams on intercompany agreements, click here.
What participants can expect to receive
Participants in this training will receive a briefing on two critical areas:
- Transfer pricing, the OECD’s initiatives to address BEPS (Base Erosion Profit Shifting), and why this is a high-priority area of the tax teams of large corporates
- The practicalities of putting in place legal agreements to support a group’s transfer pricing strategy.
The session will address the questions most commonly asked, namely:
- What is transfer pricing?
- What is BEPS?
- What does transfer pricing documentation look like?
- What are the real-world consequences of getting it wrong? (Aside from Google / Starbucks- style adverse publicity)
- What role do intercompany agreements play?
- What are the most common mistakes which corporates make in relation to intercompany agreements?
- What functions other than transfer pricing do intercompany agreements for fulfil? (Or, put another way, who else may demand to see copies of intercompany agreements, other than tax inspectors?)
- What options are there as regards the format of intercompany agreements?
- How detailed should intercompany agreements be?
- How should we manage the signature of intercompany agreements?
- What ongoing processes and systems will need to be in place?
- Where should corporates start in a project to create or update appropriate intercompany agreements?
Testimonials for other LCN Legal training events
[bq type="simple" author="Head of Tax" company="FTSE 100 Group"]"I found it refreshing to go through the technical challenges and best practice on unwinding entities, including project managing the process, with some highly skilled and experienced in- house tax and legal experts.”[/bq]
[bq type="simple" author="Director of Group Legal" company="Listed Insurance Group"]"That was the clearest explanation of Aveling Barford I’ve heard for a long time!”[/bq]
[bq type="simple" author="International Tax Manager" company="FTSE listed household name aviation group"]"Wonderful to attend and share experiences.”[/bq]
[bq type="simple" author="Head of Internal Audit" company="FTSE 100 property group"]"Very enjoyable and informative session!”[/bq]
Times and dates
The seminars will be held by telephone conference on dates to be announced.
Each seminar will run for approximately 90 minutes. Each session will have no more than 5 delegates, to allow participants to ask their own questions at the end.
How to reserve your place
To request a place on one of these seminars, please contact Sonia Polden by email at firstname.lastname@example.org or by telephone on +44 20 3286 8868. Places will be allocated on a first-come, first-served basis.