Recent transfer pricing cases such as Coca-Cola have emphasized the fact that transfer pricing policies are unlikely to be robust unless they are implemented legally. Deficiencies in legal implementation can lead to unnecessary fines, penalties, adverse TP adjustments and double taxation.
To avoid these unwanted consequences, intercompany agreements must be aligned with TP policies and documentation as regards the delineation of the transaction, the allocation of risk, the pricing, and the ownership of intangibles.
This webinar walks you through the nuts and bolts of how to review intercompany agreements, including:
A basic framework to use, when checking whether transaction types have been correctly identified and delineated
- Key clauses to look for, to ensure that contractual risk allocation aligns with TP policies
- Common mistakes and pitfalls in intercompany agreements
- Key questions to ask, when assessing whether a group’s systems for managing intercompany agreements are fit for purpose
- How to create a plan for correcting errors and filling gaps
The session is facilitated by Paul Sutton, co-founder of LCN Legal and author of the leading book on this subject, ‘Intercompany Agreements for Transfer Pricing Compliance – A Practical Guide.’