Intercompany agreements can have seemingly small defects which can cause serious problems. Our ICA Healthcheck is designed to be a quick and easy way to spot these, as Paul Sutton explains in this episode of The LCN Legal Podcast.
Discrepancies between a group’s intercompany agreements and the transactions as described in its TP documents are an ‘easy win’ for tax authorities when seeking to raise challenges. And more fundamentally, transfer pricing positions will lack substance, because the legal and commercial reality of the relevant transactions will not be as claimed.
In this episode we look at some of the main issues for consideration in this area, including:
- Why groups need to healthcheck their ICAs
- What an effective ICA should achieve
- The consequences of getting it wrong (or just not quite right)
- What a typical healthcheck involves
- The areas that are particularly complex, challenging, or likely to reveal problems in ICAs
- The problems that we most often find.