Since it is impossible for us to publish a template that covers all the particularities by country, we advise you to contact your internal or external advisor if changes are necessary. If necessary, we can verify the agreement or create one for you for a fee. Intercompany agreements are contracts between two companies or several companies or divisions owned by the same parent company.3 min Read One fine day, tax authorities knock on the door to learn about transfer pricing agreements and their documentation. Pjotr Plastic informs them that there is documentation on transfer pricing, but no intercompany agreement proves that all related companies have accepted the transfer pricing agreements. As regards intra-group supplies, it is clear that the relevant group arrangements must comply with the group`s transfer pricing policy as regards the nature of the supply, the terms of supply (including the allocation of risk) and the pricing of the supply. They must distinguish the delivery conditions appropriately from other reference points. They must also reflect the reality of how agreements are managed and managed in practice. The complexity of change control rules or imported reports from an independent trading contract does not contribute to improving a group`s transfer pricing position if it is not effectively respected. * Determine which model intercompany agreements are currently in use within the group and whether they need to be updated. * Examine which intra-group supplies would benefit most from intra-group arrangements to support the group`s transfer pricing objectives. * Select the appropriate contract template (e.g.B. global agreements, bilateral agreements, hybrid, contract plan/standard terms). * Define clear responsibilities for the creation and maintenance of appropriate templates, the establishment of signatures and the archiving of signed intercompany agreements.
* Beware of proposals for “backdate devices”. Companies that have multiple departments can benefit from intercompany agreements, as they are able to transfer goods and services to a place in the company that benefits the most without achieving negative tax results. By separating transfers of goods and services resulting from business agreements resulting from other transactions, they can help the company and its businesses interpret and analyze inventory and sales information more effectively. .