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This lady had no sympathy for transfer pricing advisers


20 August 2018

A little earlier this Summer, Xiaofang and I attended a very lovely wedding party which was held in the oldest inhabited castle in England (apparently). I got talking to one of our fellow guests, and she very kindly asked what we do. ‘We help multinational businesses to maintain the legal structures they need to comply with international tax rules.’

It’s probably a mistake to talk about transfer pricing at wedding party, and the lady was firmly of the view that large corporates are all in the business of tax dodging. According to her, multinational groups deserve no sympathy for the difficulty of trying to satisfy multiple tax administrations which all want to tax the same profits. This is a very natural view to have, given the media coverage the subject of transfer pricing usually gets.

Despite my social faux pas, I welcome these conversations, because it reminds me why we do what we do, and why we should care enough to do it well. As far as I can tell, if we collectively want the benefit of technology and healthcare and so on, we need organisations which allow people to co-operate internationally. And those organisations naturally need the ‘corporate plumbing’ to allow them to comply (as far as possible) with the relevant legal and tax rules – which are equally necessary. So the world needs ‘corporate plumbers’ like us, as much as Obi-Wan Kenobi presumably appreciates a good pair of sandals (or was it boots?). And it’s our humble duty to fulfil our responsibilities as corporate plumbers to the best of our ability.

By good fortune, on 5th September we’ll be running a live webinar on Intercompany Agreements for TP compliance. It's for Transfer Pricing professionals, international tax advisers, CFOs, in-house legal counsel, and anyone else who is responsible for ensuring that multinational groups have an effective TP compliance strategy which is rooted in legal substance.

The focus will be on how multinational groups can establish and maintain an appropriate system of Intercompany Agreements, based on our experience of working with clients in places such as Australia, China, Germany and the USA. The topics we’ll cover will include:

  • What the OECD’s Transfer Pricing Guidelines say about Intercompany Agreements
  • Common mistakes and issues
  • Why intercompany agreements are not just about Transfer Pricing
  • Examples of key terms of Intercompany Agreements
  • Practical do’s and don’t’s

The webinar is free, but spaces are allocated on a first-come-first-served basis.

To reserve your place, click here.

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Article by
Paul Sutton
LCN Legal Co-Founder

Free Guide: Effective Intercompany Agreements for TP Compliance