What is included and what is not

Included

  • Intercompany services agreement (management, administrative, technical, sales support or shared services, selected at intake)
  • Services schedule describing each service in the form tax authorities expect
  • Pricing schedule using a cost-plus, fixed-fee or allocation method, with the mark-up left as a variable for your tax adviser
  • Optional intercompany IP licence or cost-sharing clause where the services involve group IP
  • Board resolutions for each entity approving the agreement
  • Review and sign-off by a lawyer admitted in each of the two jurisdictions
  • One round of amendments after your internal review

Not included

  • Transfer pricing benchmarking, local files, master files or country-by-country reporting
  • Advice on the mark-up, withholding tax or permanent establishment risk (we flag the questions for your tax adviser)
  • Intercompany loan agreements (available on request)
  • Secondment of individuals (see the secondment agreement product)

Review levels

Workflow draft
Product priceas listed, per jurisdiction
  • Drafted on the LegalMatrix workflow from the approved clause library and your intake answers
  • Checked by the LegalMatrix legal team for consistency and completeness
  • Delivered as an editable document with a clause-by-clause note
  • Document preparation: no lawyer sign-off, no legal advice
Lawyer review and sign-off add-on
+ US$350 and upper jurisdiction; 30% of the product price for larger documents
  • A lawyer admitted where the document will be used reviews, revises and signs off
  • Enforceability check for that jurisdiction: governing law, formalities, mandatory rules
  • Reviewer's name, admission and date on the document; 20-minute call included
  • Covered by the practising entity's professional indemnity

Counterparty Contract Review, the Negotiation Playbook and the Successor Programme Document Set include lawyer review in the price. IP filings are made by registered practitioners and are not offered without one.

Who it is for

For

  • Groups with a headquarters charging subsidiaries for management or shared services
  • Companies whose tax adviser has asked for a signed intercompany agreement to support the transfer pricing file
  • Holding structures where group IP is used by operating subsidiaries

Not for

  • Arrangements with no tax adviser involved; the pricing method needs one
  • Financing arrangements between group companies

What the document does

Clause summaries. The product delivers the drafted and reviewed document, not a template.

Services and standardsDescribes the services, the standard of performance and how new services are added.
Pricing and mark-upSets the pricing method (cost-plus, fixed fee or allocation key), invoicing and currency, with the mark-up as a schedule variable.
Cost base and allocation keysDefines which costs are included and how shared costs are allocated between recipients.
Invoicing, payment and true-upProvides periodic invoicing, year-end adjustments and documentation to support the charges.
Intellectual propertyConfirms ownership of IP created in the services and licenses group IP where needed.
Confidentiality and dataProtects group information and allocates data protection roles between entities.
LiabilityKeeps liability proportionate between related parties while avoiding terms a tax authority would treat as non-arm's length.
Term, termination and transitionAllows termination on notice and sets out transition of services on exit.
Governing lawChooses the law of one of the two jurisdictions with a simple dispute clause.

How it runs

  1. Intake

    A questionnaire captures the group chart, the services actually provided, where the people sit, the pricing method agreed with your tax adviser and the two jurisdictions.

  2. First draft

    The LegalMatrix workflow produces the agreement, schedules and resolutions, with the transfer pricing variables clearly marked.

  3. Professional review

    A lawyer admitted in each jurisdiction checks enforceability, corporate approvals and any local filing or withholding registration points, and signs off.

  4. Signature

    After one round of amendments, signature-ready versions are issued for both entities with the resolutions.

  5. Record update

    GoGoTrust files the agreement in each company's minute book and contract register and diarises the annual review date.

✓
Signed off by
A lawyer admitted in each of the two jurisdictions reviews and signs off the agreement before release; the pricing method is confirmed by the client's tax adviser.

Price by jurisdiction

JurisdictionPriceWith lawyer sign-off
SingaporeUS$2,800US$3,650
Hong KongUS$2,800US$3,650
JapanUS$2,800US$3,650
TaiwanUS$2,800US$3,650
United StatesUS$2,800US$3,650
CanadaUS$2,800US$3,650
AustraliaUS$2,800US$3,650
New ZealandUS$2,800US$3,650
United KingdomUS$2,800US$3,650
MaltaUS$2,800US$3,650

Questions

Does this replace transfer pricing documentation?

No. It is the legal agreement that transfer pricing documentation describes. Tax authorities expect both: a signed agreement and a file showing the pricing is arm's length.

Who sets the mark-up?

Your tax adviser, based on benchmarking. The pricing schedule leaves the mark-up as a variable and the review note lists the questions to settle before signing.

Can one agreement cover several subsidiaries?

The product covers one provider and one recipient. Groups with several recipients usually sign a separate agreement per pair, which keeps each file clean; multi-recipient versions are quoted on request.

Is withholding tax addressed?

The agreement allocates gross-up responsibility and requires tax certificates, but the rate and treaty position are for your tax adviser.

Does it cover secondees?

No. Individuals working in another group company need the secondment agreement product, which deals with employment and immigration points.

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