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Legal Design of Intercompany Supply Chains

Intercompany Supply Chain Design

Design the matrix of legal transactions underpinning your tax and transfer pricing compliance

We help multinational groups design or validate the matrix of intercompany legal transactions which defines how associated entities interact with each other. This matrix is the essential legal foundation for transfer pricing analysis, tax compliance, operational effectiveness, regulatory compliance and asset protection.

  • Our specialists work alongside in-house tax, legal and compliance teams and leading tax advisors worldwide.
  • We leverage our experience of supporting corporates globally, and ensure that intra-group transaction flows are clearly identified and consistent with the reality of the group’s legal operations.
  • The key output of this phase of our work is a comprehensive matrix which itemizes each individual intercompany agreement, specifying the nature of the corresponding transaction, the price-setting policy to be applied, and the parties involved.
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Winner 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

Tailored Support for Corporates and their Advisers

Comprehensive Legal Solutions for In-House and Advisory Teams

Corporates

Assurance for Multinational Groups

We ensure that your group’s transfer pricing documentation for each financial year is backed up by robust, OECD-compliant intercompany agreements and corporate structures. Avoid risks of unnecessary double taxation and wasted costs caused by defective legal implementation of TP  policies, and TP documentation which does not match the legal fact pattern.

  • We provide flexible and responsive support, often based on fixed fees.
  • We work collaboratively alongside your existing tax and transfer pricing advisers.
  • We provide as much or as little help as needed.
  • Contact us to discuss your potential needs confidentially and without obligation.
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Advisers

Enhance Client Outcomes

We enable leading tax and transfer pricing advisers to provide better client outcomes. Our leading expertise in designing and managing the legal implementation of transfer pricing policies enables you to offer a joined-up, higher value service.

  • We do not offer tax or transfer pricing advice. Our services are designed to complement and enhance yours.
  • We ensure your advice is implemented legally, helping your corporate clients get the protection they need.
  • Contact us to discuss potential projects confidentially and receive indicative fee quotes, so that you can offer a joined-up solution.
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Our 5-Step Process for Tax-Audit-Ready, Transaction-Ready Intercompany Agreements

We follow a proven approach to ensure intercompany agreements and legal structures are aligned with transfer pricing policies, tax objectives, regulatory requirements and economic substance.

Scope

Identify key intercompany transaction types clearly.

Review

Review fact patterns and existing agreements.

Draft

Create agreements to meet the requirements of the OECD Transfer Pricing Guidelines.

Finalize

Finalize agreements, taking into account the needs of the wider stakeholders.

Implement

Brief directors, arrange signatures and create an audit-ready archive.

Act Now to Optimize Your Intercompany Supply Chains

Get assurance on the matrix of legal transactions underpinning your tax and transfer pricing compliance. Take action today to enhance shareholder value and streamline your operations.

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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.

Arrange a No-Obligation Consultation

Schedule a consultation with our experts to discuss how we can help you optimize the legal design of your intercompany transactions.

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