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What would you like to see in our updated book on intercompany agreements?

Intercompany Agreements

24 January 2022

We’ve decided to create a new version of our book: ‘Intercompany Agreements For Transfer Pricing: A Practical Guide’. It was first published in March 2019, and we’d like to reflect changes in transfer pricing governance and in the commercial environment since then. We also want it to much more closely reflect the content of our flagship training course. And we’re going to introduce a new look, with much greater use of graphics and charts.

Before we start work, we'd like to give you an opportunity to help shape the contents of the new book. If you have read the existing version, or taken the training course, what did you find particularly useful? On the other hand, is there anything you think we should leave out? More generally, which of the legal aspects of transfer pricing do you find most challenging or most likely to create problems for taxpayers?

To help you, here is the currently planned content:



  • Purpose of the book
  • How to use the book

Background concepts

1. Corporate structures for multinational groups – key elements

2. Corporate governance, legal entity and contract fundamentals

3. Transfer pricing fundamentals

4. Intellectual property and intangibles

5. Contractual allocation of risk and reward

Practical application

6. General principles regarding the form and content of intercompany agreements

7. Pricing clauses

8. Other clause types and drafting considerations

9. High level scoping of intercompany transactions and interpretation of transfer pricing policies

10. Reviewing intercompany agreements for alignment with TP policies

11. Managing the implementation and ongoing maintenance of agreements

Specific transaction types

12. Introduction to discussion of transaction types

13. Transactions involving services, including:

  • Central support services
  • Local support services
  • Contracting services
  • Lead contractor support services

14. Transactions involving goods

  • Supply of goods
  • Contract manufacturing
  • Toll manufacturing

15. Distribution and reseller arrangements

  • Distribution
  • Sales agents and commissionaires

16. Intellectual property licenses and franchise arrangements

  • IP licences
  • Franchises
  • R&D services

17. Profit split and cost sharing / cost contribution arrangements

18. Loans, cash pooling and other forms of financial support

  • Loan agreements
  • Loan note instruments
  • Cash pooling arrangements
  • Guarantees and guarantee fees


19. Checklists

  • Stakeholders in the management of intercompany agreements
  • Goods
  • Services
  • IP
  • Loans
  • Cost sharing / cost contribution arrangements

If you have any thoughts or suggestions, please do get in touch and let us know. We will consider all of them when we decide on the content for the new book.

Thank you very much in advance.

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Article by
Paul O’Regan

Free Guide: Effective Intercompany Agreements for TP Compliance