Intercompany Agreements for Transfer Pricing Compliance: A Practical Guide

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.