‘Intercompany Agreements for Transfer Pricing Compliance: A Practical Guide’ by Paul Sutton


Paperback: 978-1-912687-18-3
Published: March 2019
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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 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.


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.


Corporate Governance Fundamentals
A Brief Introduction to Transfer Pricing
The Role of Intercompany Agreements in Complying With the OECD’s Transfer Pricing Guidelines
Non-Transfer Pricing Drivers for Intercompany Agreements
Key Features of an Effective System of Intercompany Agreements
Interpreting Transfer Pricing Policies and Reports for the Purposes of Creating or Reviewing Intercompany Agreements
The Format of Intercompany Agreements
General Principles for Contractual Allocation of Risk and Reward
Typical Transaction Types
Pricing Clauses in Intercompany Agreements
Other Drafting Considerations Regarding Intercompany Agreements
Checklist for Functional Review of Draft Template Intercompany Agreements
Checklist for Legal Review of Intercompany Agreements


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. Law Brief Publishing website visitors can get a 20% discount by using promotional code LP20.

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