Every multinational with controlled transactions needs intercompany agreements. The OECD says so. Tax authorities expect them. Your auditor will ask for them. And yet most companies — even sophisticated ones — operate on agreements drafted years ago by lawyers unfamiliar with transfer pricing, or worse, on no agreements at all.
This pack solves that. Eight agreements covering the controlled transactions you actually have, drafted with the dual lens of contract law and TP defensibility, with commentary explaining what every clause does and why it's there.
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i.
Management & Headquarters Services Agreement
For HQ services charged to operating subsidiaries — strategic management, finance, HR, legal, IT support, executive oversight.
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ii.
Cost Sharing / Cost Contribution Agreement
For shared development of intangibles or shared service platforms across multiple group entities.
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iii.
Limited-Risk Distribution Agreement
For routine distribution arrangements — buy-sell distributors with limited functions and risks.
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iv.
Commissionaire / Sales Agency Agreement
For sales agency structures common in European entity reorganizations.
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v.
IP Licensing Agreement
For royalty-bearing licenses of trademarks, patents, technology, or know-how between group entities.
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vi.
Contract R&D Services Agreement
For research and development services performed for a related principal entity on a cost-plus basis.
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vii.
Intercompany Loan Agreement
For intercompany financing — short-term, long-term, and revolving credit facility variants included.
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viii.
Financial Guarantee Agreement
For parent or sister-entity guarantees of subsidiary debt — increasingly scrutinized post-OECD Chapter X.