Global Mobility Meets Transfer Pricing Webinar
What Happens when Functions, Assets and Risks Follow?
RBK Chartered Accountants invite you to join our upcoming webinar exploring where global mobility meets transfer pricing, and what this means for intra-group services, permanent establishment (“PE”) risk and intercompany agreements.
We will be joined by our guest speaker, Paul Sutton from LCN Legal, who will bring a legal perspective to these issues, with a particular focus on intercompany agreements supporting global mobility, secondments and intra-group services.
Specfic items covered include:
- The transfer pricing implications of remote working, international assignments, secondments and cross-border employee activities.
- The OECD’s proposed revisions to Chapter VII of OECD Transfer Pricing Guidelines on intra-group services, including the benefit test, accurate delineation, pricing and supporting evidence and how it aligns with the broader theme.
- Common transactions from an Irish transfer pricing and tax perspective, including employee cost recharges, management and shared services, IP and sales support arrangements.
- The 2025 update to the OECD Article 5 Commentary on the Model Tax Convention, on home offices and cross-border remote working, together with wider fixed-place and dependent-agent PE considerations.
- The role of intercompany agreements in supporting the intended legal, tax and transfer pricing treatment.
This event is of interest to:
- Multinational Groups with employees working remotely or temporarily across borders.
- Groups whose CEOs, CFOs or other senior decision makers are relocating or regularly working across borders.
- Groups operating international assignment, secondment or intra-company transfer arrangements.
- Businesses providing or receiving management, shared or employee-related services within a group.
- Legal, HR and tax professionals and advisors, who are involved in developing and advising on mobility programs and structuring intercompany agreements.
Speakers
Sobhana specialises in Transfer Pricing advisory and compliance, supporting clients with end-to-end TP solutions including planning, policy design and modelling, value chain analysis, documentation and audit defence. She has advised clients across a broad spectrum of industries.
Her experience includes complex advisory assignments involving operational transfer pricing, IP planning and structuring, and value chain optimisation, as well as support with Advance Pricing Agreements (APAs) and Advance Rulings. She also advises clients on the interaction of transfer pricing with their global mobility programmes. She has also helped clients navigate transfer pricing audits and tax authority negotiations.
Richard McAufield is an Associate Partner in the Tax Department, qualified since 2014, specialising in international tax advisory for corporate and private clients. He helps multinational businesses navigate cross-border structuring and expansion, including advising on Permanent Establishment risk and assisting clients designing their global mobility programmes.
Paul is a corporate lawyer with over 30 years’ experience of cross-border transactions and multinational group structures. He is the co-founder of LCN Legal and the author of “Intercompany Agreements for Transfer Pricing Compliance – A Practical Guide”.
Paul regularly works alongside tax and transfer pricing professionals, to help businesses create and maintain robust structures, and avoid misalignment between legal form, economic substance and actual operations.
Ronan holds a Master of Accounting degree from Smurfit Business School (MAcc) and is a Fellow of the Institute of Chartered Accountants in Ireland (FCA). He is also a Chartered Tax Advisor (CTA) and a member of the Institute of Taxation in Ireland (the leading representative and educational body for Ireland’s CTAs and the only professional body in Ireland exclusively dedicated to tax).
Ronan is a Partner and is the Head of Tax in RBK. He has over 20 years’ experience advising clients on all areas of tax. He has substantial experience advising on international tax, tax structuring for Irish companies expanding overseas and multinationals locating in Ireland. He also leads out RBK’s global mobility service line.
