Transfer Pricing License Agreement

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Napsala: admin | Kategorie: Nezařazené | Datum: 13. dubna 2021

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. This page explains how to calculate arm-length royalties and use reliable comparable data to strengthen your trading position or ensure compliance with your transfer prices. License a patent for royalties: If you have invented a new product, you can either market it yourself or license the intellectual property rights of third parties. If you need price-compliant intercompany agreements for your controlled transactions, we have something for you… This model is part of the LCN Legal “Toolkits” of practical resources and intercompany agreements to facilitate the conclusion of intercompany agreements to support their transfer pricing compliance by companies and transfer pricing experts. For more information about the toolkit, click here. Intellectual property royalties are payments made by a licensee to a licensee in exchange for the exploitation of the licensee`s intellectual property. The term “transfer pricing” refers to the amount of money exchanged when two or more related companies trade with each other. It is generally used compared to multinationals (MNEs) …

A patent licensing agreement is a contract that defines the conditions under which a buyer can use a licensee`s patented product. Apple US, which owns the Apple brand, licenses Apple Netherlands to use the brand only in the Netherlands. It is important to ensure that intercompany agreements respect reality, comply with transfer pricing documentation and comply with market standards. With regard to the content of intercompany agreements, we highlight three fundamental principles: the proposals aim to complement the work of transfer pricing experts in setting up appropriate transfer pricing policies for business groups – not replacing them – including functional analysis of relevant activities and comparable research. LCN Legal does not offer tax or comparable advice. The best way to develop an intercompany agreement is to take a multidisciplinary approach. Tax and financial experts develop transfer pricing documentation, but may not have the expertise to establish legal documents. Similarly, lawyers are generally in the dark about transfer pricing rules. It is therefore important to ensure that the right people and skills are on board.

One day, the tax authorities knock on the door to find out about transfer pricing rules and their documentation. Pjotr Plastic informs them that there is documentation on transfer pricing, but there are no intercompany agreements proving that all related companies have approved transfer pricing agreements. The content of intercompany agreements depends largely on the nature of the controlled transaction and the jurisdictions in which the controlled transactions take place. Complex controlled transactions, such as the licensing of intellectual property. B require detailed contracts. Contracts for simple controlled transactions, such as the provision of administrative services, are. B can be maintained easily.