After the corresponding prices have been determined, it is necessary to establish business-to-business legal documents in order to follow the transfer pricing policy and method. In order to avoid future tax burdens or tax disputes with governments, companies must adapt their business model and business practices to their legal agreements and provide the documents required by the relevant tax authorities. A model distribution agreement is included in the suite of LCN Legal`s intercompany model intercompany agreements for transfer pricing compliance. Send us an email to for information on the pricing of bid agreements and their coverage. How, then, is this reflected in the terms of the intercompany agreement, which must exist between the client (as a supplier) and the distributor of the group`s company? Below, you will find a non-exhaustive list of legal conditions considerations that may be included in a limited risk allocation agreement to reflect the sharing of risk and reward between the parties. As in any intragroup relationship, the legal structure of the agreement should go hand in hand with the analysis of tax and transfer prices (including functional analyses, comparability, VAT and customs duties). This most likely means moving from a Commission structure. Under an LRD agreement, the main company sells to a major distribution company (for example. B in the same country as the main company), and the main distribution company continues to sell through its local subsidiaries. As with all intragroup agreements, a written intercompany agreement is essential from the point of view of corporate governance. In the absence of such an agreement, the directors or senior managers of the companies concerned (particularly the distributor) do not have a clear priority to determine whether the agreement is an agreement that they are able to properly approve. Commissionairs act only as intermediaries for customers. The client pays them a commission.

In a strip-buy-sell model, it is not an agent, but a reseller (limited risk distributor/LRD) that is part of the offer. The difference is that a dealer becomes the owner of the goods. The Commission`s services are considered to be owners from the point of view of VAT. From the point of view of VAT processing, Commissionairs and LRD are therefore similar – buying and selling – but with different legal flows. In general, an LRD is a buy/sell organization that performs all distribution functions and has a limited risk profile. For this fiscal year, economists and global databases are used to identify a number of potential prizes that close parties would use to create cross-sectional royalties to be included in local books and associated party records. It is not uncommon for a large portion of a company`s tax return income to be generated by transfer pricing. There are all kinds of business reasons for setting up centralized models. The challenge from an implementation perspective is often indirect tax. Once an effective business and tax structure is defined, addressing both historical and potential risks, it is time to put the theory behind the structure in the field of practice.

One of the most common side effects of integration that cannot be fully achieved in the area of billing. For example, many invoices payable are not properly coded, so VAT is not deducted (in time). Or if the legacy system is only half-integrated into the new model, incorrect sales invoices are issued, resulting in customer problems, false tax returns and missed compliance obligations. The aim is to introduce commission rules within the framework of the dependent agency PE.

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