The best way to develop an intercompany agreement is to take a multidisciplinary approach. Tax and financial experts develop transfer pricing documentation, but may not have the expertise to establish legal documents. Similarly, lawyers are generally in the dark about transfer pricing rules. It is therefore important to ensure that the right people and skills are on board. As with any agreement that governs a complex transaction, an inter-partnered agreement should be developed or reviewed by a lawyer. While intercompany agreements do not replace the detailed information contained in transfer pricing documentation and are not mandatory in many cases, they are another instrument that companies should use to manage transfer pricing aspects of international transactions with related companies. Signed copies of all agreements are stored in a central and ardent repository, making it easier to establish agreements for documentation purposes. Apple Austria transfers its shares and customer list to Apple Germany. This model is part of the LCN Legal “Toolkits” of practical resources and intercompany agreements to facilitate the conclusion of intercompany agreements to support their transfer pricing compliance by companies and transfer pricing experts. For more information about the toolkit, click here. Transfer pricing agreements between associated companies must be formalised in intercompany agreements in order to make them legally binding, to comply with transfer pricing legislation and to ensure an appropriate line of defence against the challenges posed by tax authorities.

If you don`t, your business is seriously and unnecessarily threatened. If you need price-compliant intercompany agreements for your controlled transactions, we have something for you… It is important to ensure that intercompany agreements respect reality, comply with transfer pricing documentation and comply with market standards. Intercompany agreements can cover different controlled transactions. Here`s a common overview: the following example illustrates what can happen without transfer pricing agreements: Find out how software tools can help you manage the transfer pricing lifecycle and provide transparency, control and consistent documentation across your business. The tax authorities are not convinced that Pierre Plastic complies with transfer pricing laws. It intends to examine (i) whether the allocation of risks, assets and functions on which transfer pricing agreements were based is consistent with actual agreements and (ii) whether the associated companies have agreed to the transfer pricing agreements. Without intercompany agreements, Pjotr Plastic must now provide further evidence and convince the tax authorities that its transfer pricing position is in fact what it claims – potentially a lengthy and costly discussion. It could have been avoided… To minimize the challenges posed by global tax authorities, ONESOURCE Transfer Pricing Intercompany Agreements helps you effectively centralize and manage intercompany agreements so they can be properly generated, updated and analyzed. Optimize the creation and implementation of transfer pricing agreements with a central repository with contract management and electronic signature functions.