LCN Legal Course in Intercompany Agreements for Transfer Pricing Compliance

Course

Online

£ 1,950 VAT inc.

Description

  • Type

    Course

  • Level

    Intermediate

  • Methodology

    Online

  • Duration

    10 Weeks

  • Start date

    Different dates available

  • Online campus

    Yes

  • Delivery of study materials

    Yes

  • Support service

    Yes

  • Virtual classes

    Yes

An online learning course for International Tax and Transfer Pricing Professionals, In-house Counsel within Multinational Groups, and Lawyers in Private Practice. The course is listed by the UK’s Chartered Institute of Tax as a supplement to the ‘International Tax’ and ‘Transfer Pricing’ modules of the Advanced Diploma in International Taxation.

Facilities

Location

Start date

Online

Start date

Different dates availableEnrolment now open

About this course

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 and for minimising the risk of double taxation or adverse TP adjustments and penalties. Intercompany agreements also play an important role in various other aspects of the operation of multinational groups, including subsidiary governance, asset protection, VAT / GST compliance, customs duties and exchange control.

This course will give you a greater understanding of:

the role which intercompany agreements play in transfer pricing compliance and corporate governance;
the key components of a system for creating, reviewing and maintaining intercompany agreements for multinational groups;
contractual approaches to the allocation of risk and reward in the context of TP compliance; and
best practice in the drafting, implementation and maintenance of intercompany agreements.

Certificate of completion, with 7.5 hours’ CPD credit

This new online course has been designed for three main types of people:

In-house legal counsel within multinational groups
Transfer pricing and tax professionals
Lawyers in private practice, who have the opportunity to assist their clients with intercompany agreements

Questions & Answers

Add your question

Our advisors and other users will be able to reply to you

Who would you like to address this question to?

Fill in your details to get a reply

We will only publish your name and question

Reviews

Subjects

  • Risk
  • Compliance
  • International
  • IT risk
  • Tax
  • Webinars
  • Participants
  • Distance
  • Learning
  • Opportunity
  • Presenters
  • Questions

Course programme

COURSE STRUCTURE

A 10-week online distance learning course comprised of 10 recorded webinars which are released weekly in sequence, and which participants can access and review in their own time.

Each module is between 45 and 60 minutes’ duration, and is followed by a self-assessment questionnaire so that participants can check their understanding of the course materials.

Course participants will have the opportunity to address questions to the presenters at any time during the period of the course. Responses will be shared (on an anonymised basis) with other course participants.

CONTENT OVERVIEW

Module 1: Introduction to intercompany agreements (ICAs) and their role in TP compliance and corporate governance

Including:
  • Relevant provisions of the OECD’s Transfer Pricing Guidelines
  • The fundamentals of corporate and subsidiary governance
  • Implications of having defective ICAs and how to identify the gaps
Module 2: Key features of an effective system of ICAs

Including:
  • Starting with the end in mind: audit-ready ICAs
  • A typical process for creating, reviewing and maintaining ICAs
  • Non-transfer pricing issues affecting the form and content of ICAs
Module 3: Scoping projects for creating, reviewing or maintaining ICAs

Including:
  • Interpreting and applying TP policies to legal structures and ICAs
  • Identifying key transaction types / material intra-group supplies
  • Prioritising the creation and review of ICAs
Module 4: The format and structure of ICAs

Including:
  • Bilateral vs multilateral agreements
  • Best practice regarding drafting styles and structure of ICAs
  • The use of third party agreements for the purposes of ICAs
  • Treatment of arrangements between a company and its own branch / permanent establishment
  • Dealing with translations
  • Applicable law
Module 5: General principles for contractual allocation of risk and reward

Including:
  • The relationship between implied and express contractual terms
  • Duty defining
  • Control
  • Ownership or control of intangible assets
  • Limitation and exclusion of recourse – transfer of risk
  • Indemnities and counter-indemnities
Module 6: Typical transaction types – Services

Including:
  • Support services / back office services
  • Agents and commissionaires
Module 7: Typical transaction types – Goods

Including:
  • Key concepts: passing of risk and title, product liability and regulatory liability
  • Distribution and resale
  • Limited risk distributors and common mistakes
Module 8: Typical transaction types – Licensing of intellectual property

Including:
  • Licenses and franchise arrangements
  • Key contractual terms for intellectual property licenses
  • Relationship with sale of goods and supply of services
Module 9: Typical transaction types – Loan facilities and cash pooling

Including:
  • Bilateral loan agreements, loan notes and promissory notes
  • Overdrafts, term loans and revolving credit facilities
  • Cash pooling arrangements
Module 10: Pricing clauses

Including:
  • The relationship between transfer pricing methods and pricing clauses
  • ‘Agreements to agree’ and legal certainty in pricing provisions
  • TP / tax adjustment clauses
  • Fixed price approaches
  • Cost plus approaches – cost keys and allocation keys
  • Residual outcome approaches
  • Royalty-type approaches
Bonus module: Checklists and practical tools

How to improve efficiencies by using checklists included in the book ‘Intercompany Agreements for Transfer Pricing Compliance – A Practical Guide’ and free resources published by LCN Legal

LCN Legal Course in Intercompany Agreements for Transfer Pricing Compliance

£ 1,950 VAT inc.