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Intercompany Agreements for Transfer Pricing Compliance: A Practical Guide
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Intercompany agreements are legal agreements which define the terms on which services, products and financial support are provided between related parties. For groups which operate internationally, intercompany agreements are the essential foundation for complying with transfer pricing regulations (the international rules which determine where profits are taxed) and for minimising the risk of double taxation. The task of maintaining an effective system of intercompany agreements often falls between two stools: tax and finance professionals may receive the blame for unexpected tax assessments r...
Intercompany agreements are legal agreements which define the terms on which services, products and financial support are provided between related parties. For groups which operate internationally, intercompany agreements are the essential foundation for complying with transfer pricing regulations (the international rules which determine where profits are taxed) and for minimising the risk of double taxation. The task of maintaining an effective system of intercompany agreements often falls between two stools: tax and finance professionals may receive the blame for unexpected tax assessments resulting from transfer pricing challenges, but do not typically have the skills to manage legal documentation. Similarly, many corporate lawyers are unfamiliar with transfer pricing concepts and may not have hands-on experience of the issues involved. This book is a practical resource for finance, tax and transfer pricing professionals, and for anyone involved in designing, implementing, maintaining or reviewing intercompany agreements for multinational groups. It sets out a common-sense approach to achieving compliance so that, as far as possible, the tax, legal regulatory and governance needs of a group can be met in a holistic way. ABOUT THE AUTHOR Paul Sutton is the co-founder of LCN Legal and a corporate lawyer with over 25 years’ experience of advising international clients, including airlines, telecommunications groups and media networks. He has particular expertise in working alongside tax professionals worldwide on the design, implementation and maintenance of legal structures for large corporates. His experience includes working in KPMG’s law firm in the UK, where he worked closely with international tax teams and developed his specialism in the legal issues which underpin transfer pricing compliance. Paul has been recognised and quoted as an expert by publications such as the Financial Times, the Scotsman newspaper and Financial Director Magazine. He regularly contributes to technical publications for legal and tax professionals. Through LCN Legal he has pioneered the publication of templates and other resources for tax and finance professionals.
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