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Your Q&A with TP professionals at Michelin, Procter & Gamble and Verizon

Intercompany Agreements

24 November 2021

We are Gold Partners of this year's TP Minds West Coast conference on 8th and 9th December.

As part of that, Paul Sutton will be chairing a panel discussion on 'Practical Approaches to Avoid an Intercompany Agreement Disaster'. The panel has a stellar line-up: Adnan Begic (Head of Transfer Pricing, Asia-Pacific, Michelin), Kurt Wulfekuhler (Director, Verizon) and Jason Wiegand (Transfer Pricing Lead, Procter & Gamble). All have decades of practical frontline experience of legally implementing TP policies.

What would you like to ask the panel? Let us know: email Paul at paul.sutton@lcnlegal.com, and we'll do our best incorporate your questions into the discussion. Feel free to make your question as specific and practical as you like, as long as it’s on the subject of legal implementation of TP.

To get you started, here’s one question which was raised at our recent webinar on healthchecking intercompany agreements:

"An ICA has been signed where the principal appointed a subsidiary as a limited risk distributor and guaranteed the distributor a fixed return. But over the years the agreement was completely ignored: the principal funded all of the distributor’s operating expenses via intercompany advance, and the distributor deducted those expenses in its tax returns and incurred large losses. What would you do?"

We're looking forward to hearing your questions. And if you'd like to know more about the the conference, click here.

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Article by
Paul O’Regan

Free Guide: Effective Intercompany Agreements for TP Compliance