Archives for January 2022

There are two types of this gas, butane and propane. Butane is stored in blue cylinders and is ideal for camping, single-burner cooking appliances and portable indoor radiators. Propane, on the other hand, is stored in red cylinders and is mainly a fuel for commercial heating and large appliances, which is also ideal for heating and cooking in catering vans. The patio gas stored in green cylinders is propane, which is ideal for outdoor appliances such as grills and patio heaters. The Company will provide the User with the cylinder(s) to transport and safely store the gas supplied. This contract is not a rental agreement and does not give the user a title in the cylinder. The User will not divest himself of ownership or control of the Bottle (other than a CALOR point of sale), nor will he claim to have any rights in conflict with this Agreement, nor will he create or claim to have an agency or depot in connection with the Bottle or the User`s obligations, nor will he attempt to create an agency or depot. You must have either a cylinder in the patio to exchange or the corresponding terrace 5kg CRA. Without one or the other, Calor Gas will not be able to fulfill your order. If you have any concerns about the material that appears on our website or if you have any questions about these Terms of Use, please contact us by email at webmarketing@calor.co.uk. -our General Terms and Conditions of Use of the Site (www.calor.co.uk/terms-and-conditions); (a) www.calor.co.uk is a website operated by Calor Gas Limited (“Calor/us/we”). We are registered in England and Wales under company number 00303703 and have our registered office at Athena House, Athena Drive, Tachbrook Park, Warwick CV34 6RL.

Our contact details for products ordered on our website are: Athena House, Athena Drive, Tachbrook Park, Warwick CV34 6RL. Our email address for general questions is shop@calor.co.uk. Our VAT number is GB 207 610 984. To: Calor Gas Limited, Athena House, Athena Drive, Tachbrook Park, Warwick, CV34 6RL, (Email shop@calor.co.uk) You may not link to any part of our website without our prior written permission. If you wish to request such permission, please send an email to webmarketing@calor.co.uk. Linked websites, whether licensed or not, have no implicit affiliation with our website. If we give you permission to link to any part of our website, the website from which you link must comply in all respects with the content standards set out in our Acceptable Use Policy. 4.1 By signing this Agreement, you confirm that you have not entered into any other agreement with third parties regarding the supply of gas to your address.

You agree, as long as this Agreement exists, not to purchase gasoline from another person at your address. Without prejudice to any other contract you have entered into with us, these Terms and Conditions and all documents expressly mentioned therein (including, for the avoidance of doubt, the cylinder refill contract in which you order bottled gas) constitute the entire agreement between us with respect to the subject matter hereof and supersede any prior agreement. Understanding or agreement between us, whether verbally or in writing. You acknowledge that in entering into this Agreement, you do not rely on any representations, representations, representations or warranties not set forth in these Terms and Conditions. Propane is the preferred choice for commercial use; especially for the operation of tools, furnaces or forklifts, for example. It is also well suited to provide heat and cooking fuel for caravans or even to power a patio heater. The list of installers provided by Calor Gas Limited (“Calor”) in the installer finder is not exhaustive and other installers may be available. Any referenced installer is independent of Calor, and Calor cannot be held responsible for the treatment of an installer. Any work performed constitutes an agreement between the installer and the customer, and Calor is not involved to any extent.

The terms and conditions and warranties relating to each product purchased by the Customer from Calor remain independent of Calor`s Installer Finder. A Towsure supermarket fills the gas cylinders by providing you with a pre-filled bottle in exchange for the empty bottle. A bottle can only be exchanged for the same thing, otherwise a new bottle refill contract will be charged. This advertised price is for a refill/exchange of a CALOR brand 13kg patio gas cylinder – you need to bring or rent a Calor gas cylinder of the same size and type. We are unable to replace bottles from other manufacturers 13.2 Any notice you give us under these Terms must be emailed to us at shop@calor.co.uk. We may notify you either at the email or postal address you provided to us when placing your order, or in any of the above ways (although communication in connection with your order is not through communications on our website). 17.2When you visit our website, we issue a “cookie” that allows us to identify your computer. The cookie contains information that allows customers to navigate the website.

This information is deleted from the cookie at the end of the order process. Browsing information may be used to monitor customer traffic patterns and website usage and to help us develop the design and layout of our website. For more information on the use of cookies, please see our Cookie Policy (www.calor.co.uk/cookies). For more information about cookies, see www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies, and the websites above will show you how to delete cookies from your browser. However, some features of our website may not work. While we continue to be able to exchange comparable data cylinders that are full for void due to an ongoing shortage of gas cylinders, Calor has suspended all new cylinder leases, which means we will not be able to deliver a new cylinder until further notice. Since the beginning of the lockdown and the introduction of barbecues nationwide, the demand for terrace gas has increased by 45%, resulting in bottlenecks. The supplier`s website states that they are out of stock in different bottle sizes, including patio gas, which is used for most barbecues and patio heaters, and propane used in caravans 17.1We use the personal data you provide to us as part of your order or in correspondence or subsequent communication for the purpose of processing your order and managing your account. If you agree, we (or one of our group companies) may send you emails with details of other products or services that we believe may be of interest to you by checking the box on the order form. However, you may unsubscribe from receiving other marketing information at any time by using the unsubscribe function in any email you receive from us or by contacting us at shop@calor.co.uk.

We do not share your personal data with companies outside the Calor Group for marketing purposes. 7.7If the Product is defective or defective, you must contact us by sending us an email to shop@calor.co.uk or by calling 0800 1814512. If you contact us by email, our first action is to call you at the phone number in your order to discuss the issue with you. We will inspect the returned products and inform you by phone within a reasonable time if you are entitled to a refund. We will process the refund of defective or defective products as soon as possible and, in any case, within 14 days of our agreement that you are entitled to a refund. 7) Termination of the filling by the User This Contract will remain in force for 50 years. The User may terminate this Agreement by returning the bottle(s) in good condition to a CALOR point of sale designated for this purpose and will be entitled to a refund of part of the costs of the refill contract on presentation of this Contract as follows: – 1 year = 70% Refund 2 years = 60% Refund 3 years = 50% Refund 4 years = 45% Refund 5 years = 40% Refund 6 years = 35% Refund 7 years = 30% Refund 7 years = 30% Refund over 7 years = 25% refund – our privacy policy (www.calor.co.uk/policy) which defines how we use your personal information; The 13 kg patio gas cylinder is equipped with a gas level indicator and is the perfect solution for stocking up on patio heaters and grills/grills during the long summer evenings. 10) This Agreement shall be governed by and construed in accordance with English law. Ideal for patio heaters and large grills with 4 or more burners, it is specially designed to power outdoor appliances such as grills and patio heaters and the advantage is that it is compatible with the 27mm clip-on controller. It also has a gas tracer indicator, which is useful for determining when your gas is low. We sell terrace gas in bottles of 5 kg and 13 kg. The lack could mean problems for beginners on the grill or for those who bought the patio heater..

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This type of transaction, also known as a buyout agreement and product financing agreement, takes place between two parties. The first party “sells” its inventory to the second part, with the explicit promise to buy back the inventory at a predetermined price over time or at a later date. Pensions have traditionally been used as a form of secured loan and have been treated as such for tax purposes. However, modern repurchase agreements often allow the cash lender to sell the collateral provided as collateral and replace an identical collateral upon redemption. [14] In this way, the cash lender acts as a debtor of securities and the repurchase agreement can be used to take a short position on the security, in the same way that a securities loan could be used. [15] If companies need to raise funds immediately but do not want to sell their securities for the long term, they can enter into a buyback agreement. Such agreements are common in large banks and other large financial institutions, but they also work at the level of small businesses. Raising funds isn`t free, so understanding your potential liabilities in a buyback agreement can help you control the cost of investing extra cash on your balance sheet. In order to determine the actual costs and benefits of a reverse repurchase agreement, a buyer or seller interested in the transaction must consider three different calculations: In the case of a overnight repurchase agreement, the agreed term of the loan is one day. However, either party may extend the due date and, on occasion, the agreement has no due date at all. A repurchase agreement can be considered a secured loan. The lender provides money to the borrower in exchange for a guarantee that serves as collateral. At a later date, the borrower purchases the same collateral with the money originally received plus accrued interest Retroactive interest refers to interest generated on a debt outstanding for a certain period of time, but payment has not yet been made or.

An MSRP differs from buying/selling in a simple but clear way. Buy/sell agreements legally document each transaction separately and provide a clear separation in each transaction. In this way, each transaction can legally stand on its own, without the application of the others. RSOs, on the other hand, have legally documented each step of the agreement in the same contract and guarantee availability and entitlement at each stage of the agreement. Finally, in an MSRP, although the warranty is essentially purchased, security usually never changes the physical location or actual ownership. If the seller is in default with the buyer, the warranty will have to be physically transferred. Kevin Johnston writes for Ameriprise Financial, Rutgers University`s MBA program, and Evan Carmichael. He has written on business, marketing, finance, sales, and investment for publications such as The New York Daily News, Business Age, and Nation`s Business. He is an instructional designer with credits for companies such as ADP, Standard and Poor`s and Bank of America. Here`s a simple example of how a repurchase agreement works: The term (duration) of a repurchase agreement is called the term. There are two main types of reverse repurchase terms: The term repurchase agreement refers to a trade agreement in which one party sells inventory to a second party with the promise to buy back the inventory at a later date.

Under a buyback agreement, the selling party is able to fund its inventory without disclosing the liabilities or assets in the entity`s balance sheet. Repurchase agreements are generally considered safe investments because the security in question acts as collateral, which is why most agreements include U.S. Treasuries. Classified as a money market instrument, a repurchase agreement effectively functions as a short-term, secured, interest-bearing loan. The buyer acts as a short-term lender, while the seller acts as a short-term borrower. This makes it possible to achieve the objectives of both parties, secure financing and liquidity. Repurchase agreements are generally considered to be instruments with a mitigated credit risk. The biggest risk with a reverse repurchase agreement is that the seller cannot stop the end of his contract by not buying back the securities he sold on the due date. In these situations, the buyer of the security can then liquidate the security in an attempt to recover the money initially paid. However, the reason this poses an inherent risk is that the value of the security may have declined since the previous sale, leaving the buyer with no choice but to hold the security they never wanted to hold for the long term or sell it for a loss. On the other hand, there is also a risk for the borrower in this transaction; If the value of the security right exceeds the agreed terms, the creditor may not resell it […].

Or maybe you`re a local entrepreneur looking to grow your business and undertake larger construction projects. In any case, you need to make sure you have a written agreement to act as a plan until construction is complete to smooth out wrinkles. The fact is that construction contracts help put you and your customer on the same page. And even if you don`t stay on the same page for some reason, these contracts help ensure that you and the customer are sticking to the terms of your contractor contract. Regardless of the type of construction contract you choose for your project, there are a few key elements you need to include in your agreement, including: Suppose your contractor and his or her team have suddenly stopped working and he or she is demanding excessive payment for materials and labor that were not originally agreed. Or your client, the owner, refuses to pay you once the project is complete. In any case, you must ensure that you have a written agreement to protect your rights. If you don`t have an agreement, you risk wasting time and money, not to mention the quality of the construction. For the customer, this includes the name, company name (if applicable), telephone number, email address and address of the property (residential or commercial) where the construction work will take place.

For example, without contractual documents describing the scope of the project, you could find yourself in a situation where a client insists on additional construction services – without paying for it. Or let`s say you`re struggling to collect payment from a customer. If you don`t have a construction contract that clearly outlines your payment plan, your client may argue that they don`t have to pay you by a certain date, which can have devastating effects on your company`s finances. A change order agreement allows either party to derogate, modify or supplement the original contract with a written document signed by both parties. If you include this agreement, you can easily change the scope of your project or the terms of the contract as things change at all levels. A construction contract is a legal document that describes in detail the parameters of a construction project. The content of the agreement depends on the type of project and the type of client. For example, your contractor contract for a retail client would generally be different from a contract for a commercial client. Whatever the project or client, it is important to have a concrete contract from the start. A work stoppage clause gives you the right to stop the project if the client has not paid you. The stop payment clause gives the customer the right to withhold payment if you do not meet the milestones set for the project or if you do not perform the work at the agreed quality level.

To reassure yourself, you need to include both clauses. If you want to start with a construction project, you want to make sure you and your client are on the same page. And the best way to be on the same page – both from a project and legal perspective? Preparation of a construction contract. Homeowners can protect themselves from construction delays with a lump sum damage clause in their agreement. The lump sum compensation is a fixed amount per day that the contractor pays to the owner for each day construction is delayed. Instead of taking the damages to court, the owner and contractor can agree in advance on a lump sum of damages. A force majeure clause describes how you and the customer will move forward if you are faced with any of these unpredictable circumstances, such as a hurricane, earthquake, or widespread hardware shortage. Be sure to consider any issues that may arise. Construction Invoice – For a contractor to demand payment from their client for services rendered. The type of construction contract that is best for you depends on the project, the client, and how you want to be paid for your services. If you want to see a model construction contract for any of these types of contracts, a quick Google search for “Model Construction Contract Template” or “Free Construction Contract Template” can help you find what you`re looking for.

If it is a new building or if the project is large (more than 2-3 months), the contractor will require them to be paid overtime or at certain “checkpoints”. The client is responsible for ensuring that the project proceeds accordingly and, if certain parameters are met, for making the payment. This roadmap is intended for clients and contractors to determine the current status of the project and what points are outstanding for completion. While each project is unique, the following guide can be helpful when planning a construction project. Concrete contracts help protect your company and your client throughout the project. Without this contract, you could run into problems if one of the parties has a dispute. Before you create the contract, you need to send a quote to your customer to make sure you`re on the same page. Then include this estimate in your construction contract with a payment plan. A warranty gives your client this security by guaranteeing your work for a certain period of time (usually a year). Most customers don`t work with a contractor who doesn`t offer a warranty.

So this is definitely something you want to include in your construction contract. This agreement allows the parties to record in writing the exact nature and details of the work to be performed, as well as the responsibilities of each party throughout the construction. .

The EU encourages Brazil to remove tariff and non-tariff barriers and promote a more stable and open regulatory environment for European investors and traders. Next, the project will focus on a study on fair and equitable trade in Brazil and the organization of a second forum in December 2018. An interactive list of bilateral and multilateral free trade instruments is available on the TREND-Analytics website. [59] Promoting Trade: Catalyzing the Implementation of the Trade Facilitation Agreement in BrazilHow Would Brazil Release Billions of Dollars in Trade Growth Would Brazil Be Affected by Key Trade Agreements? Why is the Brazilian economy closed to trade? Brazil is a member of the Mercosur trading bloc, which has its own regional standardization organization that issues and harmonizes standards. Technical committees draft and recommend standards in selected areas. Each country must ratify the standard before it is adopted in that country. A number of standards have already been adopted as Mercosul standards. The standards adopted and proposed by Mercosur are listed on the Mercosur website. The Executive Secretariat of the Mercosur Organization for Standardization is located in São Paulo, Brazil. List of agreements under negotiation. Agreements that have so far only been discussed without formal action by the parties concerned are not listed.

EFTA[17] has bilateral agreements with the following countries, including dependent territories, and blocs: The United States achieved an estimated $18 billion in services trade with Brazil in 2019, down 11.6% from 2018. Describes the trade agreements in which this country is involved. Provides resources for U.S. companies to obtain information on the use of these agreements. The aim of these new international negotiations, whether with EFTA or the EU, is to give the economy an indispensable boost, not only by facilitating international trade, but also by increasing Brazilian exports. As part of the agreement and the resulting cheaper market access, it is estimated that Brazilian exports of various products from the most diverse sectors of the economy will constantly increase. In addition, non-tariff barriers will be removed to facilitate trade between the two regions. Brazil is the largest economy in Latin America and its trade with the EU accounted for 30.8% of the EU`s total trade with Latin America in 2016. The United States is working with Brazil on trade and investment issues through a number of initiatives.

The Eurasian Economic Union composed of Russia, Belarus, Kazakhstan, Armenia and Kyrgyzstan has the following free trade agreements, see below here. In 2011, the United States and Brazil signed the Trade and Economic Cooperation Agreement to strengthen trade and investment cooperation between the two largest economies in the Western Hemisphere. The agreement expands our direct trade and investment relationship by providing a framework for deepening cooperation on a number of issues of mutual interest, including innovation, trade facilitation and technical barriers to trade. Note: Every customs union, every common market, every economic union, every customs and monetary union and every economic and monetary union is also a free trade area. Brazil is among the countries that have used a large number of potentially trade-restrictive measures, according to the European Commission`s latest report. Brazil is currently negotiating a free trade agreement with the EU within the framework of the Mercosur Group. The EU is currently negotiating a free trade agreement with Brazil as part of the negotiations on the EU`s Association Agreement with the Mercosur countries (including Argentina, Uruguay and Paraguay). List of agreements between two states, two blocs or one bloc and one state. A future EU-Mercosur Association Agreement should promote trade integration between Mercosur countries and create new opportunities for trade and investment with the EU by removing tariff and non-tariff barriers and foreign direct investment. Marcos Piacitelli, Free Trade Agreement Specialist, Thomson Reuters ONESOURCE Global Trade Turkey has concluded bilateral and multilateral agreements with: The People`s Republic of China has concluded bilateral trade agreements with the following blocs, countries and their two special administrative regions:[13] For fully multilateral agreements (not included below), see: List of Multilateral Free Trade Agreements.

Switzerland (which has a customs union with Liechtenstein, which is sometimes included in agreements) has bilateral agreements with the following countries and blocs:[41] This is a list of free trade agreements between two parties, where each party could be a country (or other customs territory), a trading bloc or an informal group of countries. ==External links==The goods trade surplus with Brazil was $12.0 billion in 2019, an increase of 46.6% ($3.8 billion) compared to 2018.Afghanistan has concluded bilateral agreements with the following countries and blocs:[1] To reverse this negative trend, policymakers have put in place policies to promote exports and focus on free trade agreements with countries and blocks outside the Latin American region. By opening trade with new markets and negotiating new agreements, Brazil is ready for a wider global reach with new global partners, which ultimately improves trade relations and contributes to the growth and stability of the Brazilian economy. . U.S. services exports to Brazil were estimated at $24.6 billion in 2019, 8.4% ($2.2 billion) less than in 2018, but 81.0% more than in 2009. . In the TPR gateway, you can find explanations and backgrounds Search for documents online These links open a new window: wait for a while for the results to appear. .

Revenues from services in Brazil by U.S.-majority companies were $40.2 billion in 2017 (latest data available), while revenues from services in the U.S. by Brazilian-majority companies were $2.7 billion. The Brazilian market is highly protected with an average tariff rate of 13.5%. EFTA countries` exports totalled $400 billion in 2016, of which only 0.8% went to Brazil. In the same year, EFTA`s total imports amounted to USD 333.4 billion, of which only 0.9% came from Brazil. .

In general, a lease can be written or oral, but a lease for certain types of property must be written and signed by both parties. For example, if a tenant wants to rent real estate (land or buildings) for more than one year, the lease must be in writing. Some leases must be written, signed and recorded in a register of deeds. These leases usually concern properties that are leased for a period of more than three years. An assignment is different from a sublease. In a sublease agreement, the original tenant transfers temporary rights from the lease to a third party, but the third party does not enter into a contractual relationship with the landlord. The original tenant retains the same rights and obligations under the lease and enters into a second contractual relationship with the subtenant. Like assignments, subletting is also valid in principle, unless it is prohibited by the owner. In any state, a court can cancel an unscrupulous lease. A lease is unscrupulous if it favors one party too much over the other. Suppose a small business owner rents a property for 30 years to operate a gas station. The lease contains a clause that states that the landlord can revoke the contract without giving reasons and without notice.

If the tenant fulfills his obligations under the lease, but the landlord revokes the lease without notice, the clause that allows termination without notice can be considered unscrupulous. A decision of lack of scruples must be made by a judge or jury based on the facts of the case. The investigator may consider factors such as the relative bargaining power of the parties, other terms of the lease, the purpose of the lease, and the potential loss to either party due to the terms of the lease. Property insurance that covers loss of rental income due to property damage caused by an insured risk. • The relationship is contractual, created by a lease. for a period of years, from year to year, for life or at will and exists if a person, with the permission or consent of the landlord, occupies the premises of another person subordinate to the title or rights of the landlord. An agreement between two parties on the use of a property. B for example a personal property (car or boat) or a property (company or apartment). It can be verbal or written and should cover important points such as the start and end date of the lease, rent and any additional costs, how payments are to be made and any restrictions on the use of the property. The landlord or landlord is called the landlord and the tenant party is the tenant. A lessee may assign a lease to a third party or an assignee.

An assignment transfers to the assignor all rights under the lease for the remainder of the term of the lease, and the assignee enters into a contractual relationship with the original lessor. However, unless the lessor agrees otherwise, the first lessee retains the original obligations under the lease until the end of the lease. In principle, an assignment is effective, unless it is prohibited by the owner. An agreement that allows the tenant to purchase the leased asset after the lease term has expired. Typically, some or all of the lease payment is applied to the purchase. A lease to the property […] Agreement stipulating that a tenant has the right to purchase the rental item and the terms of purchase. If a landlord fails to meet their obligations under the lease, the tenant can sue the landlord for damages. The extent of damage may vary. If a lessor violates the lease by sending non-conforming goods or goods not ordered by the lessee, the tenant may refuse the goods, terminate the lease and sue the lessor to recover the funds already paid and the damage caused by the shipment of the non-compliant goods. If the lessee fails to comply with the obligations under the lease, the lessee may terminate the lease, withhold or cancel delivery of the goods or lease the goods to another party and to the original lessee the difference between the amount that the lessor would have earned under the original lease and the amount earned by the lessor from the new lease; recover. A lease term begins when the tenant receives a copy of the lease.

However, the lease does not have to be assigned directly to the tenant; it is sufficient for the tenant to know that the rental agreement is in the hands of a third party acting on behalf of the tenant. A lease can also take effect when the tenant takes control of the property. Commercial real estate coverage for a lease broken due to property damage resulting from a risk specified in the contract. As a rule, the tenant pays the difference between […] – ConcIu-Rent-Leasing for the duration of the lease. One granted for a period beginning after the expiry or any other provision of 11 previous leases of the same premises to another person; or in other words. in the case of the assignment of a part of the contract that entitles the tenant to all rents accrued after the date of his release from the previous lease and to grant it on appeal against the detaining party. Cargill vs. Thompson, 57 minutes….

In this context, companies should review, amend and, in some cases, reformulate their business-to-business arrangements in accordance with the revised OECD Transfer Pricing Guidelines and the content underlying their transfer pricing agreements. In the absence of an intra-group agreement, the starting point for functional analysis is the behaviour of the parties (i.e. the substance itself), which may lead tax authorities to form their own opinion on the functions, risks and expected results and on how the independent parties would behave. Well-formulated group agreements can determine which entity has the right to make these important risk management decisions. It is common for third parties to enter into legal agreements that set out the terms that govern a particular agreement/transaction. It would be very unusual for a company to enter into a significant agreement/transaction with a third party without a fully signed written legal agreement that allows each party to legally enforce the promises made at the time of closing the agreement/transaction. The absence of an intra-group agreement (or an ineffective/incomplete agreement) makes it difficult to apply step 2 of the recommended risk analysis procedure. This may raise questions as to whether transfer pricing policy has been carefully developed and implemented, taking into account the relevant guidelines. The preparation and implementation of an intra-group arrangement is a good practice for developing a transfer pricing policy in line with the OECD Transfer Pricing Guidelines. The OECD Action 13 guidelines require that a position be taken on the terms of each transaction. The OECD local file requires: (1) a description of the terms of the transaction; and (2) the results of the six-step process analysis for the precise definition of risk management, control and financing; and (3) copies of group agreements. Therefore, for the purposes of compliance with local Action 13 files, a full contract is recommended. They also have intercompany agreements in line with their typical external business agreements, which helps align agreements with the company and provides additional convenience that intercompany transactions are on market terms.

“We have had a very comprehensive review of the intercompany agreement for some time, which is mainly due to what has to do with BEPS issues.” Manuel went on to say that “the tax jurisdictions with which they have recurring audits are already very demanding. In almost all cases, we are the first to be invited to receive transfer pricing and business-to-business agreement documents at the beginning of the audit. For reasons of efficiency, the headquarters of multinational corporations (MNEs) often offer subsidiaries a variety of business-to-business support activities. Typically, these services fall into one of the broad categories of support, including human resources, finance, information technology, legal advice and marketing. With the increase in the volume of cross-border transactions and increased competition between different multinational companies, companies often centralize all intra-group services in a single low-cost location to create efficiency and avoid duplication of services. This trend has led to the creation of intra-group shared service centers. Even before the first observations under Action 13, tax authorities will start reviewing existing principles and requesting intra-group audit agreements. I spoke to Mike Manuel, Director of Transfer Pricing at Texas Instruments (TI), about his experience to date and the process of executing IT business-to-business agreements. He noted that TI has always been very diligent in respecting its business-to-business agreements. In many intercompany transactions, day-to-day risk mitigation is outsourced. A contract can prove which party controls the outsourced activity. The BEPS PROJECT has particularly focused on the regulation of intangible assets.

The above statements on the greater importance of the economic substance apply mutatis mutandis. With regard to intangible assets, it should be expressly pointed out that legal ownership alone is no longer sufficient to attribute the (residual) profits from the marketing of intangible assets to a company. As part of the audits, it is necessary to explain which company performs the economic functions (risks) with regard to development, upgrading, maintenance, protection and operation (marketing) and how important the respective functions are to the intangible asset. [9] Relevant classifications should be duly taken into account both in contract research agreements (strategic objectives, monitoring of milestones, remuneration for non-performance) and in licensing agreements (right to sub-licence, specifications and participation in commercialization activities, etc.). A fully signed group agreement (i.e. signed by both parties) can serve as an example of an official document approved by senior management to demonstrate that strong controls by the tax administration are in place. Evidence may be provided that the employees involved within an organization have gone through a process in which they have seriously reviewed and entered into an agreement on a particular intercompany agreement. This provides robust formalized control that helps ensure that relevant transfer pricing laws and guidelines are taken into account. .