Checklists – Intercompany Agreements for Transfer Pricing Compliance

Defective intercompany agreements can undermine your transfer pricing policies, and can give rise to unnecessary risks of adverse tax adjustments, fines and penalties.

This suite of practical checklists is designed to help multinational groups ensure that their intercompany agreements are aligned with their transfer pricing policies, and reflect the intended allocation of risk and pricing.

The checklists cover the following transaction types:

• business support services (including head office, back office, strategic management services, marketing services and other services not ‘resold’ to third parties)
• distribution or resale of goods
• licensing of intellectual property (including franchise-type arrangements)
• intercompany loans

The checklists are based on our practical experience of helping corporate groups internationally to put in place effective legal structures and transfer pricing agreements (also known as Intercompany Agreements or ‘ICAs’). LCN Legal’s lawyers are recognised as experts in Intercompany Agreements, and we have been featured in a range of respected journals including Tax Journal, Finance Director Magazine, Accountancy Magazine and Thomson Reuters’ Practical Law.