Despite the renewed focus by tax administrations on the legal and operational implementation of transfer pricing, some multinational groups fail to maintain a comprehensive central archive of intercompany agreements which is kept up to date and aligned with their TP policies. This creates unnecessary risks of adverse adjustments, fines and penalties in transfer pricing and tax audits.
Since its establishment in 2013, LCN Legal has helped MNEs with combined annual revenues of over USD 130 billion to avoid unnecessary fines, penalties and adverse transfer pricing adjustments, by making sure that their legal structures are aligned with their transfer pricing policies and support their commercial needs.
Our book ‘Intercompany Agreements for Transfer Pricing Compliance – A Practical Guide’ is the definitive work on the subject. Our online course on ICAs is recognised by the UK’s Chartered Institute of Tax, and by various other associations and organisations in other countries.
Around the world, large corporates and leading transfer pricing professionals choose us because we offer a unique skill set: we are commercial lawyers with an understanding of transfer pricing. This allows us to take a cross-functional approach to designing and implementing ICAs. We liaise with all the stakeholders involved (not just in tax) to ensure that the agreements support all of the group’s objectives.
To be audit-ready, groups need a comprehensive central archive of signed ICAs, which are aligned with TP policies. These then need to be kept up-to-date, through a process of regular review and revision.
Paul is the co-founder of LCN Legal and the author of “Intercompany Agreements for Transfer Pricing Compliance – A Practical Guide”. He is passionate about bridging the gap between tax and legal professionals, and helping multinational groups to create effective corporate structures for transfer pricing compliance.
Paul studied European law in the UK and Germany, trained as a corporate lawyer in the City of London, mainly advising German, Swiss and Austrian clients on acquisitions, joint ventures and commercial contracts. He qualified as a solicitor in 1994 at the firm of Pritchard Englefield, a London-based firm established in 1848. He was appointed as a partner of that firm four years later in 1998.
Paul joined KPMG’s UK law firm in 2001, and Paul developed a specialism in working alongside international tax and transfer pricing professionals on the design and legal implementation of restructuring projects for large corporates. This has included projects such as Eurobond listings, corporate migrations, cross-border mergers and intercompany agreements for transfer pricing. He later became a corporate partner in the London offices of McGrigors LLP and of Pinsent Masons LLP.
During his legal career before setting up LCN Legal in 2013, Paul successfully lead legal teams on projects for a range of well-known high profile clients, including acting for a major European airline on a business sale and joint venture, creating a franchise network for a well known European mobile phone operator, establishing various real estate and other funds, group reorganisations and corporate simplification projects for a range of household name clients, and advising a Middle Eastern Royal family on corporate structures for family investments.
Paul has been recognised and quoted as an expert by publications such as the Financial Times, the Scotsman newspaper, Financial Director Magazine and Accounting Web. He regularly contributes to technical publications for legal and tax professionals, including the Tax Journal, Tax Adviser magazine, Taxation magazine, InCompliance magazine, Today’s General Counsel, Practical Law (a Thomson Reuters resource for legal professionals), Lexis Nexis’s online resources for transfer pricing professionals and Lexis PSL’s legal resources for practicing lawyers.
Through LCN Legal, Paul has pioneered the publication of templates, checklists and other resources for tax and legal professionals. These include template intercompany agreements for transfer pricing, as well as legal guides and resources for various corporate structuring projects.
Paul is regularly asked by multinational corporates, financial institutions and professional firms to present training sessions and workshops on subjects relating to corporate and investment structures and the legal aspects of transfer pricing compliance. Through LCN Legal, he has hosted workshops and webinars on these subjects for numerous multinational corporates and tax and TP advisory firms.
Xiaofang is the co-founder and CEO of LCN Legal. She is passionate about ensuring that our clients consistently receive the best possible legal support, by listening and responding to their feedback. She is also passionate about the role of women in international business.
Xiaofang was born and grew up in Henan province, China – the birthplace of Chinese civilization with over 3,000 years of recorded history, and now a booming logistics hub of China. In 2007, she graduated with a bachelor’s law degree from the China University of Political Science and Law, Beijing, the largest institution in the World for legal education, and widely regarded as one of the top two law schools in China.
She came to the UK in 2008 and completed an LLM in International Commercial Law at the University of Edinburgh. Following her graduation she was asked to join the London Chamber of Commerce and Industry in order to help establish the Chinese Business Association (CBA) there.
Now, as CEO of LCN Legal, she leads the firm and helps it to expand its presence internationally. She is also the co-founder of Chinese Mums in Business Club.
Ivan is a Partner at LCN Legal, specialising in Intercompany Agreements for the Transfer Pricing compliance of multinational groups, corporate restructuring projects and cross border and domestic joint ventures and M&A transactions.
Ivan graduated in 1998 with a 1stClass Honours degree in Law and International Business from the University of Stirling, Scotland, before completing his legal education at the College of Law, London (with commendation). Ivan then trained and qualified as a solicitor in 2005 at the London offices of international law firm, Baker & McKenzie LLP, where he spent more than seven years specializing in complex cross border and domestic corporate reorganisations / simplification projects, mergers and acquisitions, private equity and investment structures, joint ventures and general corporate/commercial law and corporate governance advice for large corporates.
Ivan has advised a broad range of clients including those in the financial services, insurance, software/IT, SaaS, digital media, analytics, consulting services, advertising, hotels, manufacturing, pharma, chemicals and energy sectors as well as several well-known private equity and private and sovereign investment funds.
During his years at Baker & McKenzie LLP, Ivan was posted from London to the firm’s Moscow and Amsterdam offices for a combined total of three years, where he focused on international joint ventures, mergers and acquisitions and corporate, equity and debt restructuring projects.
Ivan began working closely with international tax, transfer pricing and finance professionals, focusing on the legal implementation of reorganisations for large corporates. He continued this work as an M&A and Integrations Legal Manager for Accenture from 2011 to 2014. From 2015 to 2016 he acted as Senior Group Legal Counsel for The Phoenix Group (the UK’s largest life insurance consolidator), where he gained invaluable in-house experience of large global corporate groups and in highly regulated business environments.
In recent years, Ivan has focused on international corporate structures and, in particular, Intercompany Agreements for the Transfer Pricing compliance of multinational corporates. Together with Paul Sutton and Leiza Bladd-Symms, Ivan leads LCN Legal’s practice in creating legal substance for Transfer Pricing compliance.
In addition to his corporate, M&A, restructuring and related transfer pricing experience, Ivan also brings broad corporate transactional experience in project management, commercial contracts, intellectual property, employment, tax, pensions, real estate, trade compliance, competition, litigation, anti-corruption and data privacy matters, in addition to other areas of compliance and regulation (including listed company and insurance sector regulation and supervision).
Ivan’s interests outside work include his family, sailing (RYA Coastal Skipper), surfing, skiing, SCUBA diving and international adventure travel.
Fun fact: Reading ‘Rumpole of the Old Bailey’ as a child is what inspired Ivan to become a lawyer.
A Partner at LCN Legal, Leiza focusses on advising multinational groups across a range of sectors on the creation of legal substance for transfer pricing compliance, associated international restructuring projects and as regards general corporate and commercial matters.
Leiza has built her specialist practice by working closely with tax and transfer pricing professionals in advising high profile multinational corporates on both the drafting, implementation and continuing management of intercompany agreements for transfer pricing compliance and on broader legal matters related to the same, including effective corporate governance, group reorganisations and cross-border joint venture and M&A transactions. With a client base that spans the globe, Leiza provides advice to a broad range of corporates headquartered throughout Europe, the US, Australia and the Middle East.
A regular speaker and presenter, Leiza has trained teams of international tax and legal professionals on the legal implementation of transfer pricing and contributed to LCN Legal’s “Online Course on Intercompany Agreements for Transfer Pricing Compliance” listed by the UK’s Chartered Institute of Taxation as applicable to its Advanced Diploma in International Taxation. She also acted as editor to her colleague, Paul Sutton, in his authoring of “Intercompany Agreements for Transfer Pricing Compliance – A Practical Guide”: the seminal academic publication on this subject.
Leiza joined LCN Legal from the global multinational, A J Walter Aviation, where she was Head of Legal. Prior to taking up that in-house role, Leiza worked at both Clyde & Co LLP and Magic Circle firm, Linklaters, out of London and Sao Paulo.
Oversees the operational needs of the company
Being fully conversant with all operational aspects of the business, Sonia ensures all functions run as efficiently as possible and is always working with the team to improve processes, with the ultimate goal of enhancing the client experience.
With a degree in foreign languages from the University of Bristol, Sonia has honed her business skills over an expansive career, having worked in various companies such as Tesco Head Office, the BBC, Arcadia, Novartis, Sodexo and the National Fostering Agency.
Sonia has a keen interest in property investment, cocktail-making and playing tennis.
Rebecca is a Director at LCN Legal, specialising in corporate restructuring, Intercompany Agreements for the Transfer Pricing compliance and M&A transactions as well as providing general corporate law advice.
Rebecca trained and qualified as a solicitor at Clifford Chance LLP before working for two US law firms in their London offices focussing on mergers and acquisition and joint-venture transactions alongside general corporate law advice to clients based in the UK and internationally. More recently, Rebecca worked in the legal teams at KPMG LLP and Deloitte LLP where she worked directly alongside tax, accounting and other colleagues on the legal side/legal implementation of projects. In this role Rebecca developed a deep understanding of some of the nuances of converting tax and accounting advice into legal documentation so as to ensure that the desired outcome is obtained.
Rebecca speaks fluent French having studied for a dual degree at King’s College London (LLB in English Law with French Law) and the Université de Paris I Panthéon-Sorbonne (Maitrise en Droit mention Droit Anglais).
Rebecca is passionate about supporting access to the legal profession and has been involved in careers events at sixth form colleges and schools through ‘Inspiring the Future’.
Andrew graduated at the top of his class with a 1st class honours while studying Law with Business at Nottingham Law School before graduating with Distinction on the Legal Practice Course.
Andrew trained at a boutique commercial law firm in the Midlands before moving on qualification in 2016 to Freeths LLP, a national law firm, where he gained extensive experience in corporate legal work including, mergers and acquisitions, restructures and reorganisations, joint ventures and private equity investments.
In his spare time, Andrew enjoys sport and working out and also honing his music and photography skills.
Andrea graduated with a Masters degree in Business Studies from the University of Edinburgh, Scotland, before completing her legal education at BPP Law School, London.
Andrea worked as a paralegal for several City law firms in London and in-house for NBCUniversal before working at the Belfast office of the “Magic Circle” firm Allen & Overy LLP where she qualified as a solicitor in 2020.
Andrea has a broad range of experience including in commercial contracts, intellectual property, litigation, corporate governance, risk management and compliance; previous clients include those in the pharma and FMCG sectors.
Andrea is focused on promoting diversity and inclusion in the workplace, and supporting community and charity work. Outside of work Andrea’s interests include her family, running and playing tennis.
Sandrinne studied her undergraduate degree in European Law at Maastricht University in the Netherlands before returning to London to complete her legal education at BPP Law School.
Since then, Sandrinne worked as a paralegal in the City before qualifying as a solicitor at Raymond Saul & Co. LLP, a boutique property firm where she focused on commercial and corporate property.
Sandrinne is passionate about social justice and volunteers outside of work.
Kaya has a strong background in administration, working with both SMEs and MNCs in the insurance sector before joining LCN Legal.
As an experienced Data Analyst and Catastrophe Modelling administrator, Kaya takes pride in her creative problem-solving abilities and her keen eye for detail.
Outside of work, Kaya’s interests include cooking, live music and reading.
Ian is a senior tax professional with more than 30 years’ International Corporate Tax experience and acts as a non-executive adviser to LCN Legal. Prior to this, Ian was the VP and Head of Corporate Tax EMEA for American Express. Ian now acts as a mentor to tax and other professionals, on a pro bono basis.
I worked with Paul Sutton for many years whilst he was at McGrigors / Pinsent Masons, in my role as Group Tax Manager of Sumitomo Electric Wiring Systems (Europe) Ltd (SEWS-E Ltd), and also for a period as SEWS-E Ltd Company Secretary. In this time I had extremely valuable assistance and advice from Paul, not only as regards general corporate law matters, but also particularly across a wide spectrum of legal aspects of SEWS-E Ltd group transfer pricing policies, implementation, inter-group agreements and legal compliance.
Martin L Kinsey, Group Tax Manager
Sumitomo Electric Wiring Systems (Europe) Limited
I have worked with Paul and his team in structuring significant Corporate Debt and have found his approach to be commercial, pragmatic and measured. I would have no hesitation working with Paul again, as we value his commercial and responsive approach.
Joanne Luce, Director
Acqua Trust Company Limited, Jersey
All-Fill Inc, a US based manufacturer of packaging machinery, has had the distinct pleasure of working with Ivan Hanna and the LCN Legal team in relation to our overseas acquisition projects. Ivan has displayed patience and intricate knowledge of English law as it applies to us as a foreign company. Ivan’s counsel has been calculated and sound, together we tailored an approach that is telling of our company’s aggressive nature. I was most impressed at Ivan’s willingness to dig deep into the details and investigate any way to give our side a competitive advantage while negotiating. Ivan has been our guiding light since our initial engagement.
Ryan Edginton, President & CEO
I have been working with Ivan Hanna over the past year on various corporate matters including a group share restructuring project and intercompany agreements for our transfer pricing compliance. Compared to other corporate law firms I have worked with, Ivan took the time to understand our business, our stakeholders and my needs. He was incredibly responsive and went above and beyond to manage our various stakeholders and turn around a big piece of work in a short amount of time. I have no hesitation in recommending Ivan or LCN Legal – they are what all solicitors should be!
Becky Karver, CFO
It is my privilege to recommend Ivan. He is able to process requirements quickly and formulate an effective strategy that protects one’s commercial interests. He is very personable and exceeds expectations. A great lawyer!
Roop Singh Sood, Executive Producer
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