I was honoured to participate in a TP Minds Digital panel discussion last week, on the subject of intercompany agreements for TP compliance. The headline for the session was “Can You Afford Not To Review Your Transfer Pricing Agreements In The COVID-19 Environment?”.
During the session, we discussed questions such as:
- Key points to consider when revising TP policies in response to Covid-19
- The role of intercompany agreements in protecting parent and subsidiary directors from personal liabilities
- The change over the last 10 years in the attitudes of TP professionals and tax administrations as regards intercompany agreements
- Practical implications of not maintaining and updating appropriate intercompany agreements, to respond to changes in comparables, business models, supply chains and underlying substance
- How to balance flexibility in intercompany agreements with the need to document, implement and defend a clear transfer pricing position
