LCN Legal’s ICA toolkit saves you hundreds of hours, by giving you tried and tested template agreements which you can adapt for your group. The toolkit gives you the peace of mind of working with up to date templates that have been specifically created for the purpose of supporting transfer pricing compliance.
Avoid the mistakes made by many multinational groups when implementing their transfer pricing policies
Many multinational groups fail to implement their transfer pricing compliance policies through appropriate intercompany agreements, leaving them exposed to unnecessary risks of adverse transfer pricing adjustments, fines and penalties. Often, this is because their intercompany agreements have not been prepared by specialist lawyers who are familiar with the OECD’s Transfer Pricing Guidelines and with international best practice.
Typical mistakes include:
- failure to include the legal functionality needed for transfer pricing compliance purposes;
- failure to reflect the allocation of risk intended in the group’s transfer pricing policies;
- failure to implement the intended intercompany pricing in a legally enforceable manner;
- inclusion of inappropriate contractual provisions copied from third party contracts, which do not reflect the group’s operations and which undermine the integrity of the group’s transfer pricing documentation as a whole; and
- overly long and legalistic agreements, which are unlikely to be read and understood by the key people within the group who need to input into the agreements.
Our toolkit of template intercompany agreements have been created by the authors of ‘Intercompany Agreements for Transfer Pricing Compliance – A Practical Guide‘, the seminal book on this subject. The templates have been developed over a number of years, with the benefit of feedback from tax and transfer pricing professionals across the globe.
I really like the format! It is very clear and easy to follow. Can you teach our lawyers to write so clearly? I wonder sometimes if they are being paid by the word.
— Brian Sturtz, Former Director of International Tax and Transfer Pricing, Walmart Stores, Inc., commenting on template intercompany agreements produced by LCN Legal
What does our ICA Toolkit include?
The toolkit provides access to the core documents in the LCN Legal library of template intercompany agreements, which you can tailor for your group. These comprise:
- Central support services agreement (tax, accounting, HR, legal, IT support, etc.)
- Strategic management services agreement
- Franchise agreement
- Intellectual property (IP) licence and assignment agreement
- Software licence agreement
- R&D services agreement
- Marketing services agreement
- Agency services agreement
- Shared client account services agreement (for shared client delivery)
- Secondment agreement
- Distribution of goods agreement
- Limited risk distributor agreement
- Toll manufacturing agreement
- Intercompany loan agreement
- Cash pooling agreement
- Foreign currency forward agreement
- Sample pricing provisions reflecting OECD guidance and pricing methods
Note: Documents are provided in English and are governed by English law.