Despite the renewed focus by tax administrations on the legal and operational implementation of transfer pricing, many 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.
We focus on the end result that corporates need: a comprehensive central archive of signed intercompany agreements, which is aligned with TP policies and kept up-to-date. This enables them to respond quickly and effectively to tax audits, and reduces the risks of protracted investigations, adverse TP adjustments and double taxation.