Paul Sutton and Paul O’Regan discuss LCN Legal’s 5-step process for creating and implementing ICAs. This has been developed over many years, and is designed to ensure that in a tax audit, the group's ICAs will support its TP position.
Paul Sutton explains the firm’s 5-step process for creating and implementing effective ICAs. In the course of explaining each stage in detail, he highlights the importance of:
- Ensuring that ICAs have legal substance, and integrating the legal considerations from the outset
- Understanding the precise nature of the key transactions, and establishing the ‘legal anchor points’
- Working effectively with the wider team of TP professionals
- Drafting that is brief and clear, using plain language
- Identifying and taking on board the needs of other stakeholders
- Localising agreements to reflect the needs of different countries and entitie
- Ensuring that directors have all the information they need to carry out their responsibilities
- Creating – and maintaining – a central online archive of agreements.
Want more insights on transfer pricing, legal risk, and cross-border structuring?
