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27 June 2023

Episode 7: the 5-step process for creating and implementing ICAs

Paul Sutton and Paul O’Regan discuss LCN Legal’s 5-step process for creating and implementing ICAs. This has been developed over many years, and is designed to ensure that in a tax audit, the group's ICAs will support its TP position.

Paul Sutton explains the firm’s 5-step process for creating and implementing effective ICAs. In the course of explaining each stage in detail, he highlights the importance of:

  • Ensuring that ICAs have legal substance, and integrating the legal considerations from the outset
  • Understanding the precise nature of the key transactions, and establishing the ‘legal anchor points’
  • Working effectively with the wider team of TP professionals
  • Drafting that is brief and clear, using plain language
  • Identifying and taking on board the needs of other stakeholders
  • Localising agreements to reflect the needs of different countries and entities
  • Ensuring that directors have all the information they need to carry out their responsibilities
  • Creating – and maintaining – a central online archive of agreements.

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