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Intercompany Agreement Transfer Pricing
"I need an Intercompany Agreement Transfer Pricing document for our Irish parent company and its manufacturing subsidiaries in France and Germany, focusing on cost-plus pricing methodology for manufacturing services, to be implemented by March 2025."
1. Parties: Identification of the group companies entering into the agreement
2. Background: Context of the agreement, relationship between parties, and group structure
3. Definitions: Key terms used throughout the agreement, including transfer pricing specific terminology
4. Scope of Agreement: Nature of intercompany transactions covered by the agreement
5. Transfer Pricing Methodology: Agreed method for determining prices in accordance with arm's length principle
6. Payment Terms: Terms and conditions for payments, including currency, timing, and method
7. Documentation Requirements: Required records and documentation to support transfer pricing
8. Compliance Obligations: Obligations to comply with relevant tax laws and OECD guidelines
9. Term and Termination: Duration of agreement and circumstances for termination
10. Confidentiality: Provisions for protecting sensitive pricing and financial information
11. Governing Law and Jurisdiction: Specification of Irish law as governing law and jurisdiction
12. Dispute Resolution: Procedures for resolving disputes between parties
1. Force Majeure: Optional clause for unforeseen circumstances affecting pricing arrangements
2. Intellectual Property Rights: Include when transactions involve IP or technology transfer
3. Quality Standards: Include when dealing with product manufacturing or service delivery standards
4. Performance Metrics: Include when specific performance measurements are relevant to pricing
5. Audit Rights: Optional provisions for internal or external audit of transfer pricing arrangements
6. Amendment Procedures: Include when specific procedures for price adjustments are needed
7. Tax Gross-Up: Include when withholding tax considerations are relevant
8. Local Law Compliance: Include when transactions involve multiple jurisdictions
1. Schedule 1 - Pricing Schedule: Detailed pricing methodology and specific rates for different types of transactions
2. Schedule 2 - Services Description: Detailed description of services or products covered by the agreement
3. Schedule 3 - Calculation Methods: Specific formulas and calculations used for transfer pricing
4. Schedule 4 - Documentation Requirements: Detailed list of required documentation and maintenance procedures
5. Schedule 5 - Group Companies: List of all group companies covered by or potentially joining the agreement
6. Appendix A - Transfer Pricing Methods: Detailed description of approved transfer pricing methods and their application
7. Appendix B - Compliance Checklist: Checklist for ensuring ongoing compliance with transfer pricing requirements
8. Appendix C - Functional Analysis: Analysis of functions, assets, and risks of each party
Authors
Arm's Length Principle
Associated Enterprise
Comparable Uncontrolled Price
Controlled Transaction
Cost Plus Method
Documentation Requirements
Effective Date
Financial Year
Force Majeure Event
Group
Independent Enterprise
Intellectual Property Rights
Intercompany Services
Irish Revenue
Master File
Local File
OECD Guidelines
Parent Company
Performance Obligations
Pricing Methodology
Related Party
Resale Price Method
Service Provider
Service Recipient
Subsidiary
Taxes Consolidation Act
Tax Authority
Transfer Pricing Method
Transfer Pricing Policy
Transactional Net Margin Method
Uncontrolled Transaction
Working Day
Profit Split Method
Functional Analysis
Comparable Analysis
Transfer Pricing Adjustment
Business Restructuring
Compliance Requirements
Documentation Package
Economic Circumstances
Fair Market Value
Functions, Assets and Risks
Governing Law
Intra-group Transaction
Market Conditions
Operating Margin
Profit Level Indicator
Related Party Transaction
Service Agreement
Testing Party
Transaction Value
Scope of Agreement
Transfer Pricing Methodology
Pricing Adjustments
Documentation Requirements
Compliance Obligations
Payment Terms
Performance Obligations
Service Levels
Quality Standards
Record Keeping
Audit Rights
Information Exchange
Confidentiality
Data Protection
Intellectual Property
Term and Duration
Termination
Force Majeure
Change Control
Assignment and Subcontracting
Dispute Resolution
Governing Law
Jurisdiction
Notices
Entire Agreement
Severability
Amendments
Tax Compliance
Group Membership
Warranties
Indemnification
Review and Adjustment
Reporting Requirements
Regulatory Compliance
Technology
Pharmaceutical
Manufacturing
Financial Services
Professional Services
Retail
Consumer Goods
Automotive
Energy
Telecommunications
Life Sciences
Media and Entertainment
Industrial Products
Healthcare
Legal
Finance
Tax
Treasury
Compliance
Risk Management
Corporate Development
International Operations
Financial Planning & Analysis
Transfer Pricing
Tax Director
Chief Financial Officer
Transfer Pricing Manager
International Tax Manager
Corporate Counsel
Finance Director
Group Financial Controller
Tax Compliance Manager
Head of Treasury
Legal Counsel
Risk Manager
Corporate Finance Manager
Financial Planning Manager
Group Tax Accountant
Compliance Officer
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