Agreement Branch Office

The first and most obvious point is that it is not possible for there to be a legally binding intercompany agreement (ICA) with a single party and that, therefore, the risks cannot be contractually attributed. However, it is generally useful to document the relationship between the ”parent” and his ORE and the risk distribution envisaged. As a general rule, a group`s transfer pricing guidelines do not contain the required level of detail. We generally prefer to use a document in the form of a typical ICA. The main reason for this is that there is evidence that other similar operations within the group concerned are carried out on equivalent terms (where possible). Provided that the ”agreement” clearly indicates on its face that it is not legally binding, it should not be possible for it to be considered misleading in any way. Some of the large companies we work with follow this approach. This agreement is governed by the laws of Tasmania and each party is subject to the jurisdiction of the Tasmanian courts. These terms of use (”Conditions”) govern your use of our website (”Website”) and constitute a binding agreement between you, the user of the website and the branch (”TBO”). You should make sure that you read these conditions carefully and contact us if there are any questions before using the site. You can contact us at the or call us on 03 6332 9300 if you have any questions. This question came up last week during a transfer pricing project (thanks to AH and NA for the increase!). The question was how to document the relationship between the ”parent company” and its own institution (PE) – and in particular the use of a memorandum in relation to a document in the style of an agreement.

TBO assumes no responsibility for losses or damage caused by the use of this site. TBO may change these Terms of Use of this website at any time without notice. By using the site, you agree to be linked to the current version of these conditions. You keep the currency of the information in your account, including contact information and promotional content. From a legal point of view, the style or format of the document makes no difference and the OECD guidelines on transfer pricing do not appear to express opinions or recommendations in any way.