In this episode, we delve into the critical role that intercompany agreements play in the realm of transfer pricing and global business operations. As businesses navigate the complexities of today's economic landscape, these agreements serve as essential tools for delineating risk and spelling out the intentions of the parties to the transaction.
While attending the 2024 NABE (National Association for Business Economics) Transfer Pricing Symposium, our host, Brittany Hardin Tanguay, spoke with participants to share their thoughts on the topic. Join Brittany as she, along with our guest Mark Horowitz (Principal, Tax Controversy and Dispute Resolution – KPMG US), react to the thoughts of other transfer pricing practitioners on the nuances of intercompany agreements. Brittany and Mark discuss the evolution of intercompany agreements, the importance of clear risk allocation, and the necessity of maintaining flexibility to adapt to unforeseen circumstances. Discover how businesses can effectively manage their intercompany agreements to to help secure better resolutions within tax disputes.
Transfer Pricing
Guidance on compliance, documentation, and strategy
KPMG report: HMRC guidance on OECD’s control of risk framework
Implications that HMRC guidance has for transfer pricing policies
DEMPE Across the Globe
A review of global applications of the control of risk framework