This webinar is for finance, tax, transfer pricing, legal and compliance professionals, and focusses on the treatment of intangible assets and intellectual property in the context of intercompany agreements for Transfer Pricing compliance.
This webinar is for finance, tax, transfer pricing, legal and compliance professionals, and focusses on the treatment of intangible assets and intellectual property in the context of intercompany agreements for Transfer Pricing compliance.
A practical perspective on HMRC v BlackRock for tax professionals, focusing on what the case means for group structure design and intercompany agreements — and why legal theory shapes transfer pricing decisions in multinational groups.
Why intercompany agreements fall through the cracks between legal and transfer pricing teams, and how a proactive, cross-functional approach keeps a group audit-ready — from spotting gaps to defending your position during an audit.
A short case law briefing on HMRC v BlackRock: the fact pattern, HMRC’s challenge on transfer pricing and unallowable purpose, and how the courts approached covenants, security and control — plus what it all means for groups managing intercompany loans.