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Where's your allotment?

Intercompany Agreements

29 September 2020

Allotment (noun) a plot of land rented by an individual for growing vegetables or flowers.

In my ignorance, I thought that allotments were something quintessentially British. But it turns out that it’s a phenomenon that exists all over the world. The one pictured above is in the village of Lindfield, West Sussex, where we live.

I’m not an allotment gardener myself, but there’s something very wholesome about people doing their gardening work in public. Maybe because it’s not just about people providing for themselves. It’s also about being part of a community.

Some of the 'virtual allotments’ in the corporate world that I admire include Keith Brockman’s blog Strategizing Multinational Tax Risks, the prolific output of articles written by Dr Harold McClure (including for our own blog), as well as the TP newsletters of a number of tax and accounting firms.

LCN Legal’s humble allotment includes our Guide to Maintaining Effective Intercompany Agreements for TP Compliance. It originated in an article which was written for Tax Journal back in 2013, and has now grown to 29 pages, including FAQs and a case study. An offshoot of it turned into our book on intercompany agreements, and our online course. We’ve also recently created a series of free checklists for intercompany agreements for the most common transaction times. You can download the latest version of the guide here, and the checklists are available here.

Personally, I think transfer pricing is still in the Stone Age when it comes to cultivating value, because (with some exceptions) it’s still very disjointed from other disciplines. Not so long ago, my colleagues and I facilitated a workshop for one of the major multinational investment banks, including their ‘head of subsidiary governance’. It had not even occurred to that person that transfer pricing was a relevant issue to address.

Until we do a better job in raising awareness of how different processes need to connect with each other, TP concepts such as ‘control of risk’ will be condemned to remain as theoretic concepts which are applied in the abstract, with little substance.

I certainly need all the help I can get in expanding my knowledge. Whose work do you admire, which should be shared more? What initiatives have you contributed to, which should be known more widely? Please drop me a line at info@lcnlegal.com and let me know.

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Article by
Paul Sutton
LCN Legal Co-Founder

Free Guide: Effective Intercompany Agreements for TP Compliance