Transfer Pricing Service Agreement

Intercompany agreements are particularly important for intangible capital agreements. In point 67 of the OECD`s revised discussion on intangible capital transfer pricing of July 30, 2013, it states that “legal rights and contractual agreements are the starting point for any analysis of transfer pricing of transactions involving intangible assets … It is therefore good practice for related companies to set out in writing their decisions and intentions with respect to the allocation of significant rights to intangible assets. 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. Although it is easier to implement global agreements, they have the disadvantage of having more difficulty meeting the specific requirements of local jurisdictions without disclosing the “special regime” to all relevant tax authorities. Theme: the nature of the goods, services or financing to be provided; Guarantees and compensation: including service levels, warranties for the maintenance or specification of goods, etc. and limitations of liability: the existence or absence of restrictions on the action of one party against the other. 8. Applicable legislation and formal conditions: check whether the agreement contains a clear legal choice and that legal advice has been sought in all areas where the formal requirements are not clear. If you need price-compliant intercompany agreements for your controlled transactions, we have something for you…

Import existing intercompany agreements and build standard templates that can be customized for each global transaction in any jurisdiction. Avoid repeated data entry and use built-in logic to speed up the design process. There is no need to restart contracts from scratch, and the reference rules will help you correct errors. In other cases, it may not be possible to say that the corresponding regulations were already in place, but it may nevertheless be desirable to achieve a “retrodated” effect. In this situation, it may now be possible to reach an agreement with a historical “effective date.” For example, a group may move from a property sales model (where local subsidiaries hold or acquire the legal personality of the products concerned and resell them to commercial risk customers) to an agency model (in which local subsidiaries act only as introductory intermediaries and without credit or other commercial risks when selling the products). The seller/order giver may agree with local distributors to process the agreements as they had been in force since the end of the previous year.

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