This briefing is for you if you are a Finance, Tax or Transfer Pricing professional and you need to put in place appropriate intercompany agreements for a multinational group, to avoid unnecessary adjustments, fines and penalties.
It’s based on our 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.
Topics covered include:
- What are Intercompany Agreements (ICAs)?
- Who says that multinational groups need ICAs?
- Isn’t the functional analysis more important than Intercompany Agreements?
- What are the consequences of not having appropriate ICAs in place?
- Can we put off implementing ICAs until we need to deal with a tax challenge?
- Can we backdate Intercompany Agreements?
- What challenges do corporates face when implementing Intercompany Agreements?
- What end result should multinational groups be aiming for?
- How should groups prioritise which Intercompany Agreements to implement first?
- What are the main areas of legal input which are required for Transfer Pricing compliance?
- What general principles should be followed when preparing and implementing ICAs?
- How long should Intercompany Agreements be?
- Why do we need briefing notes for local boards and signatories of Intercompany Agreements?
- Can we use electronic signatures to implement ICAs?
- What ongoing processes does a group need to have in place for ICAs?