The latest episode of our podcast is now out. In it we discuss how to review intercompany agreements to ensure alignment with TP policies.
Discrepancies between a group’s intercompany agreements and the transactions as described in its TP documents are an ‘easy win’ for tax authorities when seeking to raise challenges. And more fundamentally, transfer pricing positions will lack substance, because the legal and commercial reality of the relevant transactions will not be as claimed.
In the podcast episode we look at some of the main issues for consideration in this area, including:
- Why groups need to check their ICAs periodically
- What an effective ICA should achieve
- The consequences of getting it wrong (or just not quite right)
- What a typical Healthcheck involves
- The areas that are particularly complex, challenging, or likely to reveal problems in ICAs
- The problems that we most often find.
You can access the episode on our website here, or wherever you get your podcasts. You are also welcome to use our free healthcheck tool, which helps users to carry out an effective review of specific agreements, by following a systematic series of steps. You can access the tool here.
If you’d like to discuss specific issues affecting a group you’re looking after, just get in touch with us to arrange a consultation.
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