Fundamentals of Intercompany Agreements (ICAs) for Transfer Pricing Compliance

Paul Sutton is a corporate lawyer with over 30 years' international experience. He specialises in intercompany agreements and legal structures for multinational groups and financial institutions. He is the co-founder of LCN, and the author of “Intercompany Agreements for Transfer Pricing Compliance – A Practical Guide” which is published by Law Brief Publishing.

Paul works alongside leading international tax and transfer pricing professionals globally, helping to make sure that the transfer pricing policies of the groups concerned have legal substance and are implemented through appropriate intercompany agreements - which are kept up to date, and tax audit-ready and due diligence-ready.

Dritton brings more than 16 years of dedicated transfer pricing experience, having worked across Australia as a Big 4 director and in-house TP manager for two of Australia’s largest multinationals.

He has a special interest in transfer pricing funding and intangibles, and previously led Australia and Asia on PwC’s Global financial transactions leadership team. Dritton also oversaw the intangibles and innovation TP strategy while working in-house with a large Australian multinational.

Abbas Raza is a Senior Manager within Bennett Thrasher’s Tax practice. He has been involved with a variety of different tax, accounting and finance projects, assisting clients in a number of industries. The types of engagements Abbas helps deliver include:

• Providing transfer pricing consulting services to align business objectives with domestic and foreign transfer pricing rules, including comparable benchmarking, intangible asset valuation, cost allocations, value chain analysis, economic and financial modeling and documentation.
• Providing credit studies to determine appropriate intercompany financing arrangements for multiple real estate transactions, which include debt capacity, creditworthiness and interest rate benchmarking analyses.
• Providing state and local tax advisory services to a variety of businesses and industries by helping implement internal procedures and technology solutions for sales tax compliance at the state and local level.