This is a workshop specifically for TP professionals, to talk through the legal implementation of transaction types involving local sales entities.
The webinar covers mini case studies to go through the following issues:
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.