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Intercompany Agreement Transfer Pricing

Intercompany Agreement Transfer Pricing Template for Ireland

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Key Requirements PROMPT example:

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."

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Document background
The Intercompany Agreement Transfer Pricing document is essential for multinational enterprises operating in or through Ireland that need to establish compliant transfer pricing arrangements between group entities. It is specifically designed to meet Irish legal requirements while incorporating OECD Transfer Pricing Guidelines and EU regulations. The agreement is typically implemented when establishing new intercompany relationships, updating existing pricing arrangements, or ensuring compliance with recent legislative changes. It includes detailed provisions for pricing methodologies, documentation requirements, and compliance procedures, making it a crucial document for risk management and tax compliance. The agreement helps demonstrate to tax authorities that transfer pricing arrangements are conducted at arm's length and properly documented in accordance with Irish and international requirements.
Suggested Sections

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

Optional Sections

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

Suggested Schedules

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

Alex Denne

Head of Growth (Open Source Law) @ tiktok³ÉÈË°æ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co
Relevant legal definitions




















































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Relevant Industries

Technology

Pharmaceutical

Manufacturing

Financial Services

Professional Services

Retail

Consumer Goods

Automotive

Energy

Telecommunications

Life Sciences

Media and Entertainment

Industrial Products

Healthcare

Relevant Teams

Legal

Finance

Tax

Treasury

Compliance

Risk Management

Corporate Development

International Operations

Financial Planning & Analysis

Transfer Pricing

Relevant Roles

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

Industries








Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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