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Drafting of Relevant Intercompany Transfer Pricing Agreements

Guidance released by the Organisation for Economic Co-operation and Development (OECD) in October 2015 as part of the OCED’s Base Erosion and Profit Shifting (BEPS) Action Plan, prescribes specific documentation to be prepared and maintained by multinational enterprises to support the pricing of their intercompany transactions.

Rely on us to assist you with the drafting of these agreements.

The specific documentation prescribed includes:

A list of “important agreements” related to intangibles for insertion into the multinational Group’s Master File; and

Copies of all “material intercompany agreements” in the Local Files of the respective Group affiliates.