We have created a specific policy model for intercompany services. It helps you create rules for implementation in each organization. We`ve created a series of simple Word file templates for the most common controlled transactions. You can download them directly, just adapt them to your situation and use it as often as you like! The tax authorities are not convinced that Pierre Plastic complies with transfer pricing laws. It intends to examine (i) whether the allocation of risks, assets and functions on which transfer pricing agreements were based is consistent with actual agreements and (ii) whether the associated companies have agreed to the transfer pricing agreements. Without intercompany agreements, Pjotr Plastic must now provide further evidence and convince the tax authorities that its transfer pricing position is in fact what it claims – potentially a lengthy and costly discussion. It could have been avoided… To minimize the challenges posed by global tax authorities, ONESOURCE Transfer Pricing Intercompany Agreements helps you effectively centralize and manage intercompany agreements so they can be properly generated, updated and analyzed. Optimize the creation and implementation of transfer pricing agreements with a central repository with contract management and electronic signature functions. An intercompany agreement (also known as an “intragroup agreement” or “transfer pricing agreement”) is a (signed) contract between two or more related companies. This contract governs the terms (CG) of controlled transactions, such as the provision of goods or services from a company linked to another associated company. The IRS pre-price and mutual agreement program has received some constructive feedback on the proposed proposal and provides for regular revisions as it will have more experience in using the model. The IRS is still looking for comments on the model it has published.
For more information, see www.irs.gov/businesses/corporations/apma.