Few subjects in TP seem to be as misunderstood as intercompany agreements and group contracting models. This can lead to TP policies which make no sense.
I came across a good example last week, in a TP report produced by the Los Angeles office of a Big Four firm. The report benchmarked manufacturing support services which it stated were provided by the US parent to a European subsidiary. But the report failed to describe the group’s contracting model. And while the US parent does supervise third party manufacturers, the European subsidiary was not a party to any of the manufacturing or supply agreements with those third parties. So there’s no ‘service’ provided by the parent to the subsidiary in that regard.
We’re launching a new series of monthly online workshops, to help air these issues, debunk misconceptions, and open up a discussion on how the wider TP and legal communities can work better together to protect our clients. The workshops will be held on the third Thursday of each month, in three time zones (for APAC, Europe and the Americas).
The first will be held on Thursday 17th February, and you are very welcome to join. Here are the times for the three sessions: click the headings to register.
APAC
Melbourne: 1700. China: 1400. Singapore: 1400. India: 1130.
Europe
GMT: 1400. CET: 1500. USA Eastern Time: 0900.
Americas
Eastern Time 1500. Central Time: 1400. Mountain Time: 1300. Pacific Time: 1200.
In this first workshop, we’ll cover:
- A recap on the basics of intercompany agreements
- What is needed for agreements to be tax audit-ready
- Common errors and misconceptions
- FAQs
I hope you can make it, and I look forward to seeing you.
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