COMPLETE INTER-COMPANY AGREEMENT TEMPLATES
Create your own transfer pricing compliant agreements with ease...
There is a quick and easy way to create inter-company agreements, without needing a lawyer or tax expert.
- Meet your obligations with transfer pricing compliant contracts...
- Apply the most affordable method for creating solid agreements...
- Adjust them to your needs , and re-use as often as you want...
Why do you need Intercompany Agreements?
- ...Formalize your transfer pricing (without this, it is useless)
- …Protect yourself from Audits and Scrutiny
- …Create clarity for management and different departments
…We have created templates for the most common inter-company transactions.
…a simple and elegant solution with many benefits
Our templates have the Following Characteristics:
- Direct download of a word file (.docx) without restrictions...
- Clear drafting notes explaining what to fill in where...
- Flexible, compliant and self explanatory...
- No complex formatting (easy to customize)
- Use as often as you like...
“Thank you so much Wesley!
I really appreciate that you forwarded this agreement! I was leaning towards implementing this ourselves as the companies are related and not much damage can come from getting the contract or the policy a bit wrong, as long as we are compliant. This contract will help us tremendously!
Have a great weekend!
Alex”
“Our new US accountants were happy with our TP method proposal thanks to the great templates and information provided on your website. We were therefore able to defer a more comprehensive transfer pricing analysis to a later stage when the US business is taking off. Transfer Pricing Asia has helped us enormously to jump over the pond and I can highly recommend Transfer Pricing Asia!”
The Creators
Martijn de Lange LL.M. (hons)
Martijn is a transfer pricing expert with more than 12 years of professional experience working in London, the Netherlands and Hong Kong.
He started his career at the international tax department of Deloitte. He then obtained a position as a tax lawyer at Loyens & Loeff, a renowned tax law firm in the Netherlands. While there, Martijn successfully expanded the firm’s transfer pricing practice in the Netherlands and Asia. He then continued to work as an in-house Tax Director at a listed multinational, assuming responsibility for tax matters in the Asian region, and co-founded Transfer Pricing Asia. Besides his continued involvement in Transfer Pricing Asia, Martijn now works as an insurance broker specialised in tax insurance.
Martijn often lectures and publishes on transfer pricing. His key accomplishments include:
- Development of a two-day course called: Dealing with Transfer Pricing in Asia, that he presented to senior professionals and government regulators in both Manila and Hong Kong.
- Speaker at the IFA Asia-Pacific Regional Tax Conference (Singapore).
- Speaker at the UIA Congress (Macau).
- Contributor to numerous articles in publications such as the Asia-Pacific Tax Bulletin, International TP Journal, BNA, Reuters and Bloomberg.
Martijn holds degrees in Tax Law (hons) and Corporate Law from Leiden University in the Netherlands.
Wesley Thysse Msc.
Wesley is a transfer pricing expert with more than a decade of professional working experience in Europe and Asia.
Wesley started his career in finance. He worked as a project controller at Multi Real Estate, a large developer of iconic shopping malls in Europe. He later settled in Dubai where, as a corporate service provider, he assisted entrepreneurs and high-net-worth individuals with international tax planning and legal structuring.
In 2014, he moved to Asia and started a small consultancy firm. He has since helped 100’s of SME’s and HNW-individuals with international tax and transfer pricing issues. In 2016, he started the website “Transfer Pricing Asia” to serve the region. It is now visited by more than 10,000 finance and tax professionals per month.
Wesley holds a Msc. degree in Management from the University of Greenwich, London.
The Options
We covered the most common controlled transactions. If you need a different type of transfer pricing agreement, let us know.
Inter-company Services Agreement
The provision of inter-company services is the most common controlled transaction.
This contract is applicable to the provision of the following services:
- Management fees…
- HQ services, such as legal, tax, treasury, HR, insurance, and more…
- Support services, such as accounting, customer support, technical support, IT, marketing and sales, and more…
Inter-company Loan Agreement
The provision of inter-company loans is a common controlled transaction. This contract formalizes standard financing arrangements between different members of one group.
It allows for flexibility in interest rates, payment conditions, duration, repayment, and all other essentials of a financing contract.
Note: it contains no clauses regarding security rights and different ranks of creditors (but these can be added).
Inter-company LRD Agreement
The provision of services by a Low-Risk Distributor (LRD) is a common controlled transaction.
A LRD is a buy/sell organization that performs all relevant sales and distribution functions but assumes limited risks.
A LRD undertakes many of the same activities as a regular distributor; however, the primary distinction between the two is the degree of involvement in strategic and marketing decisions. As a results it also avoids the associated risks.
Inter-company Sales Agreement
The sale of goods between companies within the same group is a common controlled transaction.
This inter-company sales agreement contains the most relevant clauses, such as a description of the goods sold, conditions for delivery, warranties and of course the arm’s length price.
If your multinational enterprise is active in the cross-border sale of goods or inventory, this is the contract you are looking for.
Frequently Asked Questions
These agreements are designed to be valid in countries all around the world. They contain all the key elements for the contract to be valid.
As it is impossible for us to publish a template that covers all country specific particularities, we advise to check with your internal or external counsel if amendments are required. If needed we can review the agreement or create one for you for a fee.
Transfer pricing documentation substantiates transfer pricing arrangements. However, it is not legally binding. Intercompany agreements help you to formalize the transfer pricing arrangements in a legally binding contract between associated enterprises.
Other than certainty within your business, this also creates evidence towards the tax authorities that transfer pricing arrangements have been implemented and formalized correctly.
There is not one set of requirements that applies to all transfer pricing agreements in all jurisdictions. Even the OECD does not provide specific guidance on what information must be included in transfer pricing agreements. This makes sense; their guidance is for countries around the world, with different legal systems and focus areas.
Moreover, there is tremendous freedom for private parties to design agreements (freedom of contract). Our agreements contain all the essential aspects such as parties, scope, controlled transaction and arm’s length remuneration. Moreover, clear drafting notes are included. Other than that, the agreements can be adjusted to suit your needs.
There are many important considerations, but we highlight three of them:
- Ensure that the agreement is in line with reality; if you invoice a cost+ mark-up of 4% while an agreement states 6%, this can raise eyebrows. This might seem obvious, but over time such discrepancies often happen within enterprises.
- Similar to the above; ensure that the agreement is consistent with TP documentation. If the conclusion of TP documentation is that a royalty fee should be 5% of the annual net revenues while the agreement provides for a royalty fee of 15%, this will probably not be accepted by the tax authorities.
- Ensure that the agreement incorporate market standards: The starting position with transfer pricing is that associated enterprises should transact with each other as if they were third parties. Hence, you expect market standard terms and conditions in the agreement. For example, if third party lenders normally require a borrower to provide securities for the repayment of the loan, it wouldn’t make sense to leave that out in an agreement between associated enterprises.
What if You Don't Like it?
If you don’t like our product for any reason, we’ll give you a full refund and you can keep the agreement. You’re not risking a cent. Due to administrative reasons, we must limit the money back guarantee to 30 days.
This guarantee eliminates all risk on your end so you have nothing to worry about. You can rest easy knowing that you’re safe and protected with this wonderful investment in yourself.
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Do not Hesitate...
This is the most convenient, affordable, and low-risk way to obtain solid inter-company agreements.
The next step is to choose your option below and click on the “Buy Now” button. Checkout is done by Paypal. After payment, you’ll be redirected to an instant download page. In addition, You’ll receive a notification by email with a link to the correct material.
Start you transfer pricing journey today…!
Kind regards,
Wesley Thysse
Managing Partner of Thysse de Lange Limited
P.s. if you need a different transfer pricing agreement, contact us…
Services Agreement
Transfer pricing compliant inter-company services agreement. Correctly formalize all your inter-company services.
- Direct download
- Clear drafting notes
- Flexible, compliant and self explanatory…
- Use as often as you like
Price: 97 USD
Loan Agreement
Transfer pricing compliant inter-company loan agreement. Correctly formalize all your inter-company loans.
- Direct download
- Clear drafting notes
- Flexible, compliant and self explanatory…
- Use as often as you like
Price: 97 USD
LRD Agreement
Transfer pricing compliant inter-company LRD agreement. For the provision of low-risk distribution activities.
- Direct download
- Clear drafting notes
- Flexible, compliant and self explanatory…
- Use as often as you like
Price: 97 USD
Sales Agreement
Transfer pricing compliant inter-company Sales agreement. For the sales of goods and inventory within the same group.
- Direct download
- Clear drafting notes
- Flexible, compliant and self explanatory…
- Use as often as you like
Price: 97 USD
Agreement Package
If you buy all these transfer pricing agreements together today, you’ll get a 50% discount on the entire package!
- Receive the Services, Loan, LRD & Sales Agreements
- Direct download
- Clear drafting notes
- Use as often as you like
