Intercompany agreements — do I need an adviser, or can I do it alone?
Some of it, yes — and we will say so on the call if that is the honest answer. The parts that are worth paying for are the ones where a missed election, a missed deadline or an unverified threshold costs more than the fee: the agreements should record the services or property, the pricing mechanism, the risk allocation and the term, and they should match the conduct and the invoices.
What if I have already filed and got it wrong?
That is a common starting point. We re-derive the position, identify whether an amendment or a disclosure route is the right vehicle, and tell you which one preserves the relief that is still available. The order matters more than the speed.
How long will it take?
It depends on the documents rather than on us. Once the pack is complete most filings turn around inside a fortnight; anything that needs a certificate from a tax authority runs on that authority's timetable, which we tell you at the start rather than at the end.
Why does an intercompany transaction need a written agreement?
A written intercompany agreement sets out what each party is actually providing, on what terms, and for what consideration, which is the evidence tax authorities expect to see behind a transfer pricing position. Without one, the economic substance of the arrangement has to be reconstructed after the fact from conduct and invoices, which is a weaker position than having the terms documented when the arrangement began.
Does the pricing in an intercompany agreement need to match actual conduct?
Yes, and a mismatch between what the agreement says and how the parties actually behave is one of the more common weaknesses found on review. We check that invoicing, service delivery, and risk allocation in practice line up with what the agreement describes, and flag where either the agreement or the conduct needs to be adjusted so the two stay consistent.
How often should intercompany agreements be reviewed and updated?
An agreement drafted for one stage of a group's operations can become outdated once functions, assets, or risks shift between entities, so it needs revisiting whenever the underlying arrangement changes materially rather than being treated as a one-time document. We review existing agreements against current operations periodically to catch that kind of drift before it undermines the pricing position.
What is an advance pricing arrangement?
An agreement with a tax authority, in advance, on how a category of intercompany transactions will be priced for a set number of years. Unilateral arrangements bind one country; bilateral or multilateral ones bind both sides of the transaction and are what actually removes the risk of an adjustment in one country without relief in the other. They take real time and full disclosure, so they suit large recurring flows rather than one-off transactions. See our transfer pricing work.
What is double taxation in a corporation?
That is the economic form: the company pays tax on its profit, then the shareholder pays tax again on the dividend distributed out of that same after-tax profit. Domestic systems soften it with dividend credits or reduced rates on distributions; across borders it is compounded by withholding tax in the paying country. Which relief applies turns on the entity type and the treaty article covering dividends. See repatriating profits.
