Paul Sutton and Paul O’Regan discuss LCN Legal’s 5-step process for creating and implementing ICAs. This has been developed over many years, and is designed to ensure that in a tax audit, the group's ICAs will support its TP position.

Paul Sutton explains the firm’s 5-step process for creating and implementing effective ICAs. In the course of explaining each stage in detail, he highlights the importance of:

• Ensuring that ICAs have legal substance, and integrating the legal considerations from the outset

• Understanding the precise nature of the key transactions, and establishing the ‘legal anchor points’

• Working effectively with the wider team of TP professionals

• Drafting that is brief and clear, using plain language

• Identifying and taking on board the needs of other stakeholders

• Localising agreements to reflect the needs of different countries and entities

• Ensuring that directors have all the information they need to carry out their responsibilities

• Creating – and maintaining – a central online archive of agreements.

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